Information Security: Department of Homeland Security Needs to	 
Fully Implement Its Security Program (17-JUN-05, GAO-05-700).	 
                                                                 
The Homeland Security Act of 2002 mandated the merging of 22	 
federal agencies and organizations to create the Department of	 
Homeland Security (DHS), whose mission, in part, is to protect	 
our homeland from threats and attacks. DHS relies on a variety of
computerized information systems to support its operations. GAO  
was asked to review DHS's information security program. In	 
response, GAO determined whether DHS had developed, documented,  
and implemented a comprehensive, departmentwide information	 
security program.						 
-------------------------Indexing Terms------------------------- 
REPORTNUM:   GAO-05-700 					        
    ACCNO:   A29397						        
  TITLE:     Information Security: Department of Homeland Security    
Needs to Fully Implement Its Security Program			 
     DATE:   06/17/2005 
  SUBJECT:   Computer security					 
	     E-government					 
	     Information resources management			 
	     Information security				 
	     Information systems				 
	     Internal controls					 
	     Performance measures				 
	     Strategic information systems planning		 
	     Systems evaluation 				 
	     DHS Visitor and Immigrant Status			 
	     Indicator Technology Program			 
                                                                 

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GAO-05-700

United States Government Accountability Office

 GAO	Report to the Ranking Minority Member, Committee on Homeland Security and
                       Governmental Affairs, U.S. Senate

June 2005

INFORMATION SECURITY

 Department of Homeland Security Needs to Fully Implement Its Security Program

                                       a

GAO-05-700

[IMG]

June 2005

INFORMATION SECURITY

Department of Homeland Security Needs to Fully Implement Its Security Program

                                 What GAO Found

DHS has not fully implemented a comprehensive, departmentwide information
security program to protect the information and information systems that
support its operations and assets. It has developed and documented
departmental policies and procedures that could provide a framework for
implementing such a program; however, certain departmental components have
not yet fully implemented key information security practices and controls.
For example, risk assessments-needed to determine what controls are
necessary and what level of resources should be expended on them-were
incomplete. Elements required for information system security plans-which
would provide a full understanding of existing and planned information
security requirements-were missing. Testing and evaluation of security
controls-which are needed to determine the effectiveness of information
security policies and procedures-were incomplete or not performed.
Elements required for remedial action plans- which would identify the
resources needed to correct or mitigate known information security
weaknesses-were missing, as were elements required for continuity of
operations plans to restore critical systems in case of unexpected events.
The table below indicates with an "X" where GAO found weaknesses. In
addition, DHS had not yet fully developed a complete and accurate systems
inventory.

Weaknesses in Information Security Practices and Controls of Selected DHS
Components

DHS component Risk assessment Security plan Security test and evaluation
Remedial action plans Continuity of operations

                                       a

                            US-VISIT n/a n/a n/a n/a

                        ICE                         X         X             X 
                        TSA                         X         X             X 
                        ICE         X               X                       X 
                        TSA         X               X         X             X 
                       EP&R         X     X                   X             X 

Sources: GAO analysis of DHS information for United States Visitor and
Immigrant Status Indicator Technology (US-VISIT), Immigration and Customs
Enforcement (ICE), Transportation Security Administration (TSA), and
Emergency Preparedness and Response (EP&R).

aFor US-VISIT, GAO reviewed only the security plan.

Shortfalls in executing responsibilities for ensuring compliance with the
information security program allowed these weaknesses to occur. Although
DHS has an organization that is responsible for overseeing the component
implementation of key information security practices and controls, its
primary means for doing so-an enterprisewide tool-has not been reliable.
Until DHS addresses weaknesses with using the tool and implements a
comprehensive, departmentwide information security program, its ability to
protect its information and information systems will be limited.

                 United States Government Accountability Office

Contents

  Letter

Results in Brief
Background
Department of Homeland Security's Mission and Organization
DHS Has Developed and Documented an Information Security

Program, but Weaknesses in Implementation Remain
Conclusions
Recommendations for Executive Action
Agency Comments

1 2 3 4

12 20 21 21

Appendixes

                                         Appendix I: Scope and Methodology 23
            Appendix II: Comments from the Department of Homeland Security 25
                       Appendix III: GAO Contact and Staff Acknowledgments 31

Table Table 1:	Weaknesses in DHS Selected Components' Information Security
Practices and Controls

Figure Figure 1:	Overview of the Department of Homeland Security's
Organizational Structure

Contents

Abbreviations

CIO Chief Information Officer
CISO Chief Information Security Officer
DHS Department of Homeland Security
FISMA Federal Information Security Management Act
IT information technology
NIST National Institute of Standards and Technology
OIG Office of the Inspector General
OMB Office of Management and Budget
US-VISIT United States Visitor and Immigrant Status Indicator

Technology

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separately.

A

United States Government Accountability Office Washington, D.C. 20548

June 17, 2005

The Honorable Joseph I. Lieberman
Ranking Minority Member
Committee on Homeland Security and Governmental Affairs
United States Senate

Dear Senator Lieberman:

Information security is a critical consideration for any organization that
depends on information systems and computer networks to carry out its
mission. It is especially important for government agencies, where
maintaining the public's trust is essential. Federal agencies face
increasing
security risks from viruses, hackers, and others who seek to disrupt
federal
operations or obtain sensitive information that is stored in federal
computers. In our reports to Congress since 1997-most recently in
January 20051-we have identified information security as a
governmentwide high-risk issue.

Responding to current and potential threats to homeland security is one of
the federal government's most significant challenges. To address this
challenge, the Homeland Security Act of 2002 (Pub. L. No. 107-296)
mandated the merger of 22 federal agencies and organizations with
homeland security-related missions to create the Department of Homeland
Security (DHS). Since it became operational in March 2003, DHS has not
only faced the challenge of protecting the homeland, but also with
transforming this collection of diverse entities into a single new cabinet
level department. In order to meet this challenge, it is crucial that DHS
establish an effective information security program to protect the
information and information systems that support its operations and
assets.

In response to your request, our objective was to determine whether DHS
had developed, documented, and implemented a comprehensive,
departmentwide information security program. To accomplish this
objective, we reviewed pertinent information security policies, procedures
and practices in place at the department and its component organizations
from information system security managers and other key officials. Our
review of DHS's information security program was based in part, on the

1GAO, High Risk Series: An Update, GAO-05-207 (Washington, D.C.: January
2005).

requirements of the Federal Information Security Management Act of 2002
(FISMA)2 and relevant Office of Management and Budget (OMB) policies3 and
National Institute of Standards and Technology (NIST) guidance related to
performing risk assessments, developing information security plans,
testing and evaluating security controls, documenting remedial action
plans, and documenting and testing continuity of operations plans. Details
on our scope and methodology are included in appendix I.

We performed our review at DHS facilities in the Washington, D.C.,
metropolitan area, Denver, Colorado, and at our headquarters in
Washington, D.C., from July 2004 through May 2005, in accordance with
generally accepted government auditing standards.

Results in Brief	DHS has not fully effectively implemented a
comprehensive, departmentwide information security program to protect the
information and information systems that support its operations and
assets. It has developed and documented departmental policies and
procedures that could provide a framework for implementing a
departmentwide information security program; however, certain departmental
components have not yet fully implemented key information security
practices and controls. For example, components' weaknesses in
implementing the program included incomplete risk assessments for
determining the required controls and the level of resources that should
be expended on them; missing required elements from information system
security plans for providing a full understanding of the existing and
planned information security requirements; incomplete or nonexistent test
and evaluation of security controls for determining the effectiveness of
information security policies and procedures; missing required elements
from remedial action plans for identifying the resources needed to correct
or mitigate identified information security weaknesses; and incomplete,
nonexistent or untested continuity of operations plans for restoring
critical systems in the case of unexpected events. In addition, DHS had
not yet fully developed a complete and accurate systems inventory.

2Federal Information Security Management Act of 2002, Title III,
E-Government Act of 2002, Pub. L. No. 107-347, Dec.17, 2002.

3Office of Management and Budget, Circular A-130, Appendix III, Security
of Federal Automated Information Resources (Washington, D.C.: Nov. 28,
2000).

Shortfalls in executing the responsibilities for ensuring compliance with
the departmentwide information security program allowed the weaknesses
that we identified to occur. Although the Chief Information Security
Officer (CISO) has responsibility for overseeing DHS components'
compliance with key information security practices and controls, the
primary means for doing so-an enterprise management tool known as Trusted
Agent FISMA-has not been reliable. The DHS Office of the Inspector General
(OIG) identified weaknesses with this tool that make it unreliable for use
in overseeing the components' reported performance data on their
compliance with key information security activities. Specifically, the OIG
reported that the data are not comprehensively verified, there is no audit
trail capability, material weaknesses are not consistently reported or
linked to plans of actions and milestones, and plans of actions and
milestones that have been identified and documented are not current. Until
DHS addresses these weaknesses and fully implements a comprehensive,
departmentwide information security program, its ability to protect the
confidentiality, integrity and availability of its information and
information systems will be limited.

To assist DHS in fully implementing its program, we are making
recommendations to the Secretary of DHS to fully implement key information
security practices and controls and to establish milestones for developing
a comprehensive information systems inventory and for verifying the
department's reported performance data. In providing written comments on a
draft of this report, DHS generally agreed with the contents of the report
and described actions to implement its security program.

Background	To address the challenge of responding to current and potential
threats to homeland security-one of the federal government's most
significant challenges-Congress passed, and the President signed, the
Homeland Security Act of 2002.4 This act mandated the merger of 22 federal
agencies and organizations into DHS. Not since the creation of the
Department of Defense in 1947 has the federal government undertaken a
transformation of this magnitude. In March 2003, DHS assumed operational
control of about 209,000 civilian and military positions from these 22
federal agencies and organizations. Each of these agencies and
organizations brought with it management challenges, distinct missions,
unique information technology

4Public Law 107-296 (November 25, 2002).

infrastructures and systems, and its own policies and procedures. Because
of the importance of the department's operations and the challenges
associated with creating the federal government's third largest
department, we designated the implementation and transformation of DHS as
a highrisk area in January 2003.5

  Department of Homeland Security's Mission and Organization

DHS's mission, in part, is to prevent and deter terrorist attacks within
the United States,6 reduce the vulnerability of the United States to
terrorism, and to minimize the damage, and assist in the recovery, from
terrorist attacks that do occur.7 This is an exceedingly complex mission
that requires coordinated and focused effort from the federal government,
state and local governments, the private sector, and the American people.
The Department of Homeland Security Appropriations Act of 2005,8 provided
$28.9 billion in net discretionary spending for DHS to carry out its
mission.

To accomplish its mission, the Homeland Security Act of 2002 established
five under secretaries with responsibilities over directorates for
management, science and technology, information analysis and
infrastructure protection, border and transportation security, and
emergency preparedness.9 Each directorate is responsible for its specific
homeland security mission area. DHS aligned the 22 federal agencies and

5GAO, High-Risk Series: An Update, GAO-03-119 (Washington, D.C.: January
2003).
66 U.S.C. S: 113(a).
76 U.S.C. S: 111(b).
8Pub. L. No. 108-334 (Oct. 18, 2004).
96 U.S.C. S: 113(a).

organizations into 13 major agency components10 (see fig. 1). The 13
components and their missions:

o 	Office of Management-responsible for such things as the budget,
appropriations, expenditure of funds, accounting and finance, procurement,
and information technology.

o 	Science and Technology-serve as the primary research and development
arm of DHS with a focus on catastrophic terrorism- threats to the security
of our homeland that could result in large-scale loss of life and major
economic impact.

o 	Transportation Security Administration-protect the nation's
transportation systems by ensuring the freedom of movement for people and
commerce.

o 	Customs and Border Protection-manage, control, and protect the nation's
borders at and between the official ports of entry.

o 	Immigration and Customs Enforcement-prevent acts of terrorism by
targeting the people, money, and materials that support terrorist and
criminal activities. It is the largest investigative arm of DHS.

o 	Federal Law Enforcement Training Center-prepare federal, state, local,
and international law enforcement professionals to fulfill their
responsibilities safely and proficiently, ensuring that training is
accomplished in the most cost-effective manner.

o 	Emergency Preparedness and Response-ensure that our nation is prepared
for incidents-whether natural disasters or terrorist assaults-and oversees
the federal government's national response and recovery strategy.

10DHS aggregates the 13 major agency components' data and reports on the
department's compliance with the Federal Information Security Management
Act of 2002 (FISMA). However, as shown in figure 1, the Transportation
Security Administration, Customs and Border Protection, Immigration and
Customs Enforcement, and Federal Law Enforcement Training Center report to
the Under Secretary Border and Transportation Security; and the Under
Secretary Border and Transportation Security is not a separate component
for FISMA reporting.

o 	Information Analysis and Infrastructure Protection-help deter, prevent,
and mitigate acts of terrorism by assessing vulnerabilities in the context
of continuously changing threats.

o 	Citizen and Immigration Services-promote national security, eliminate
immigration case backlogs, improves customer services, and provide
administrative services such as immigrant and nonimmigrant sponsorship,
work authorization and other permits, and naturalization of qualified
applicants for U.S. citizenship.

o 	Office of the Inspector General (OIG)-serve as an independent and
objective inspection, audit, and investigative body to promote
effectiveness, efficiency, and economy in the DHS's programs and
operations, and to prevent and detect fraud, abuse, mismanagement, and
waste in such programs and operations.

o 	U.S. Coast Guard-protect the public, the environment, and U.S. economic
interests in the nation's ports and waterways, along the coast, on
international waters, or in any maritime region, as required to support
national security.

o 	U.S. Secret Service-protect the President and our nation's leaders, as
well as our country's financial and critical infrastructures.

o 	United States Visitor and Immigrant Status Indicator Technology
(US-VISIT)- a DHS program intended to collect, maintain, and share
information on foreign nationals through Immigration and Customs
Enforcement and Customs and Border Protection systems in order to expedite
the arrival and departure of legitimate travelers, while making it more
difficult for those intending to do harm to our nation.

Figure 1: Overview of the Department of Homeland Security's Organizational
Structure

Source: GAO analysis of DHS organizational structure.

Within the Office of the Under Secretary Management is the Office of the
Chief Information Officer (CIO). Under the authorities of the
Clinger-Cohen Act of 1996,11 FISMA, and DHS management directives, the DHS
CIO is responsible for ensuring compliance with federal information
security requirements and reporting annually to the DHS Secretary on the
effectiveness of the department's information security program. The CIO
designated the CISO, under the authorities of FISMA,12 to carry out
specific information security responsibilities that include

1140 U.S.C. S: 11315. 1244 U.S.C. S: 3544 (a)(3).

o 	developing and maintaining a departmentwide information security
program, as required by FISMA;

o 	developing departmental information security policies and procedures to
address the requirements of FISMA;

o 	providing the direction and guidance necessary to ensure that
information security throughout the department is compliant with federal
information security requirements and policies; and

o 	advising the CIO on the status and issues involving security aspects of
the departmentwide information security program.

In addition, the CISO is responsible for oversight functions such as those
required to ensure that DHS has departmentwide, repeatable, and robust
processes for meeting federal information security requirements and that
the components accurately assess their security postures.

Information system security managers at each of the components are
expected to assist the CISO in carrying out its oversight functions.
Security managers have the role of maintaining the confidentiality,
integrity, and availability of the DHS programs and systems that support
the department's missions and operations. They are responsible for
providing the link between the departmentwide information security program
and the components. Security managers are also responsible for ensuring
that the information system security officers and program officials at
their respective components are in compliance with federal information
security requirements and policies.

Information system security officers serve as the focal point for
information security activities at the system level in each DHS component.
Among other things, security officers have the responsibility for ensuring
that appropriate steps are taken to implement information security
requirements for information systems throughout their life cycle. Security
managers directly report to the CIO at their respective component and
security officers directly report to their program officials, who directly
report to their respective component heads. Program officials are required
to implement information security controls and manage risk for information
assets pertaining to their business need.

    DHS Uses a Variety of Systems to Support Its Mission Operations

The department uses a variety of major applications and general support
systems to support its operations. A major application is one that
requires special attention due to the risk and magnitude of harm resulting
from the loss, misuse, or unauthorized access to or modification of the
information in the application. A general support system is an
interconnected set of information resources under the same direct
management control that shares common functionality. It normally includes
hardware, software, information, data, applications, communications and
people and can be, for example, a local area network or communications
network.

Many of these applications and systems serve specific requirements unique
to individual component's missions and result in interoperability issues,
data management concerns, and incompatible environments or
duplicative/inefficient processes. As noted in DHS's March 2004
Information Resource Management Strategic Plan, DHS's CIO has established
the goal of forming one network and one information technology
infrastructure to facilitate information sharing within the department and
among DHS and external federal, state, and local agencies.

    Information Security is Critical for Agencies to Effectively Accomplish
    Their Missions

Information security is a critical consideration for any organization that
depends on information systems and computer networks to carry out its
mission. It is especially important for government agencies, where
maintaining the public's trust is essential. 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, they
also pose enormous risks that make it easier for individuals and groups
with malicious intent to intrude into inadequately protected systems and
use such access to obtain sensitive information, commit fraud, disrupt
operations, or launch attacks against other computer systems and networks.

Protecting the computer systems that support critical operations and
infrastructures has never been more important because of the concern about
attacks from individuals and groups, including terrorists. These concerns
are well-founded for a number of reasons, including the dramatic increase
in reports of security incidents, the ease of obtaining and using hacking
tools, the steady advance in the sophistication and effectiveness of
attack technologies, and the dire warnings of new and more destructive
attacks to come.

Computer-supported federal operations are likewise at risk. Our previous
reports,13 and those of agency inspectors general, describe persistent
information security weaknesses that place a variety of critical federal
operations, including DHS, at risk of disruption, fraud, and inappropriate
disclosure.

    FISMA Authorized and Strengthened Information Security Requirements

Enacted into law on December 17, 2002, as Title III of the E-Government
Act of 2002, FISMA authorized and strengthened information security
program, evaluation, and reporting requirements. FISMA assigns specific
responsibilities to agency heads, chief information officers, and
Inspectors General (IG). It assigns responsibilities to the OMB as well;
these include developing and overseeing the implementation of policies,
principles, standards, and guidelines for information security; reviewing
agency information security programs at least annually; and approving or
disapproving these programs.

FISMA requires each agency to develop, document, and implement a
departmentwide information security program. This program should establish
security measures for the information and information systems that support
the operations and assets of the agency-including those provided or
managed by another agency, a contractor, or another source. This program
is to include

o 	periodic assessments of the risk and magnitude of harm that could
result from the unauthorized access, use, disclosure, modification,
disruption, or destruction of information or information systems;

o 	risk-based policies and procedures that cost effectively reduce
information security risks to an acceptable level and ensure that
information security is addressed throughout the life cycle of each
information system;

o 	subordinate plans for providing adequate information security for
networks, facilities, and systems or groups of information systems;

13See, for example, GAO-05-207; DHS, OIG, DHS Needs to Strengthen Controls
For Remote Access to Its Systems and Data, OIG-05-03 (November 2004); GAO,
Information Security: Improving Oversight of Access to Federal Systems and
Data by Contractors Can Reduce Risk, GAO-05-362 (Washington, D.C.; April
2005); and DHS, OIG, Inadequate Security Controls Increase Risks to DHS
Wireless Networks, OIG-04-27 (June 2004).

o 	periodic testing and evaluation of the effectiveness of the agency's
information security policies, procedures, and practices;

o 	a process for planning, implementing, evaluating, and documenting
remedial actions that are taken to address any deficiencies in the
agency's information security policies, procedures, and practices; and

o 	plans and procedures to ensure continuity of operations for information
systems that support the operations and assets of the agency.

FISMA also establishes a requirement that each agency develops, maintains,
and annually updates an inventory of major information systems that the
agency operates or that are under its control. Among other things, this
inventory is to identify the interfaces between each system and all other
systems or networks with which it communicates, including those that are
not operated by, or under the control of, the agency.

Each agency is also required to undergo an annual, independent evaluation
of its information security program and practices, including control
testing and compliance assessment. Evaluations of nonnational security
systems are to be performed by the agency's IG or by an independent
external auditor; evaluations related to national security systems are to
be performed only by an entity designated by the agency head. Agencies are
to report annually to OMB on the results of their independent evaluations.
OMB then summarizes the results of the evaluations in a report to selected
congressional committees.

Other major provisions require NIST to develop, for systems other than
national security systems, (1) standards to be used by all agencies to
categorize their information and information systems based on the
objectives of 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. NIST must also develop (1) a
definition of and guidelines concerning the detection and handling of
information security incidents and (2) guidelines developed in
coordination with the National Security Agency for identifying an
information system as a national security system.

  DHS Has Developed and Documented an Information Security Program, but
  Weaknesses in Implementation Remain

Since DHS became operational in March 2003, the CISO has developed and
documented departmental policies and procedures that could provide a
framework for implementing an agencywide information security program;
however, certain DHS components had not yet fully implemented key
information security practices and controls, as required by the program.
The CISO has taken several actions to develop and document a
departmentwide information security program. These actions include

o 	development, documentation, and dissemination of DHS information
security policies and procedures, strategic program plans, risk management
plans, and a management directive and handbook for the components' use in
implementing the requirements of the program;

o 	establishment of Information System Security Managers and Information
System Security Officers positions to implement DHS's information security
program departmentwide;

o 	documentation and issuance of specific guides to assist security
managers and security officers in aligning their individual components'
information security programs with the department's program;

o 	development of Trusted Agent FISMA and a digital dashboard as tools to
aggregate and report component and department level data for enterprise
management and oversight of the departmentwide information security
program; Trusted Agent FISMA is an enterprise compliance and oversight
tool that manages the collection and reporting of the components'
information associated with key information security practices and
controls, and the digital dashboard aggregates the data collected in
Trusted Agent FISMA and is used as a visual tool using a traffic light
display to gauge the progress of the departmentwide information security
program; and

o 	development and documentation of a departmentwide systems inventory
methodology that is designed to be used to develop, maintain, and annually
update an inventory of information systems operated by the department or
under its control.

In addition, as part of the department's efforts to develop and document a
departmentwide information security program, the CISO finalized the
Information Security Program Strategic Plan in April 2004, which

provides a framework for establishing a unified, departmentwide
information security program.

    Implementation Weaknesses Place DHS's Operations and Assets at Risk

Although the CISO has made significant progress in developing and
documenting a departmentwide information security program, certain DHS
components have not yet fully implemented key information security
practices and controls as required by the program. We identified
weaknesses in information security documentation for the three major
applications and three general support systems that we selected for review
that place DHS's operations and assets at risk. Among other things, DHS's
program requires the components to maintain information security
documentation in accordance with FISMA requirements, OMB policies, and
applicable NIST guidance. However, we identified that risk assessments
were not complete, security plans lacked required elements, test and
evaluation of security controls were either not comprehensive or not
performed, plans of action and milestones lacked required elements, and
continuity of operations plans were not complete, lacked required
elements, or had not been tested. In addition, DHS had not yet fully
developed a complete and accurate information systems inventory. As a
result of these weaknesses, DHS's ability to protect the confidentiality,
integrity, and availability of its information and information systems was
limited.

Table 1 indicates with an "X" where we found weaknesses in selected
components' information security practices and controls.

Table 1: Weaknesses in DHS Selected Components' Information Security
Practices and Controls

        DHS         DHS       Risk             Security   Remedial Continuity 
                                               test and   action           of 
      System     component assessment Security evaluation  plans   operations 
                                      plan                         
       Major     US-VISIT     n/a        Xa       n/a       n/a       n/a     
    application                                                    
       Major        ICE                            X         X         X      
    application                                                    
       Major        TSA                            X         X         X      
    application                                                    
      General       ICE        X                   X                   X      
      support                                                      
      system                                                       
      General       TSA        X                   X         X         X      
      support                                                      
      system                                                       
      General      EP&R        X         X                   X         X      
      support                                                      
      system                                                       

Source: GAO analysis of information security documentation for United
States and Immigrant Status Indicator Technology (US-VISIT), Immigration
and Customs Enforcement (ICE), Transportation Security Administration
(TSA), and Emergency Preparedness and Response (EP&R) systems.

aFor each system, we obtained and reviewed all documentation contained in
the certification and accreditation package-with the exception of
US-VISIT-in this case, we reviewed only the security plan.

Risk Assessments	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 policies
and controls that have been adopted, which helps ensure that these
policies and controls operate as intended. FISMA requires agency's
information security programs to include 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 that support the operations and assets of the
agency.

Risk assessments for three of the five systems were not complete. For
example, two general support systems-one at Transportation Security
Administration and one at Immigration and Customs Enforcement-had risk
assessment reports that were in draft and incomplete. In addition to the
weaknesses we identified, the OIG, as part of its fiscal year 2004 FISMA
evaluation, identified that risk assessments for selected DHS systems that
they reviewed were not current. Unless DHS performs periodic risk
assessments of its information systems, it will not have assurance that

appropriate controls over potential threats have been identified to reduce
or eliminate the associated risk.

Security Plans	The purpose of an information system security plan is to
provide an overview of the security requirements of the system and
describe the controls that are in place or planned for meeting those
requirements. The information security plan also delineates the
responsibilities and expected behavior of all individuals who access the
system. The information security plan can be viewed as documentation of
the structured process of planning adequate, cost-effective security
protection for a system and should form the basis for the system
authorization, supplemented by more specific studies as needed. According
to NIST guidance, security plans should include all interconnected systems
(including the Internet) and interaction among systems in regard to the
authorization for the connection to other systems or the sharing of
information. Also according to NIST guidance, security plans should
include rules of behavior and reflect input from various individuals who
have responsibility for the system, including information system owners.
In addition, the security plans require periodic reviews, modifications,
and milestone or completion dates for planned controls.

The information security plans for two of the six systems we reviewed
lacked required elements. Specifically, the information security plan for
a US-VISIT major application did not include authorizations for
interconnected systems or the sharing of information for primary and
secondary systems and for other infrastructures. In addition, the Internet
was not included in the list of interconnected systems. Further, rules of
behavior, another required element for security plans, did not cover all
pertinent elements such as work at home, dial-in access, connection to the
Internet, use of copyrighted works, unofficial use of government
equipment, the assignment and limitation of system privileges, and
individual accountability. The information security plan for the general
support system at the Emergency Preparedness and Response directorate did
not identify a designated information system owner or procedures for
reviewing the information security plan and following up on planned
controls. The OIG, as part of its fiscal year 2004 FISMA evaluation, found
that security plans for the DHS systems that it had selected for review
had either not been updated or not approved. As a result of these
weaknesses, DHS does not have assurance that its information systems are
adequately protected.

Testing and Evaluation	Another key element of an information security
program is periodic testing and evaluation of the effectiveness of
information security policies, procedures, and practices. FISMA requires
that the frequency with which an organization should conduct testing and
evaluation will depend on the level of risk. This testing and evaluation
should be conducted at least annually and include testing of management,
operational, and technical controls of every system identified in the
agency's information systems inventory. Management control testing, for
example, includes integration testing, which occurs in the program's
actual operating environment and tests such things as connectivity with
other systems and networks. Periodically testing and evaluating the
effectiveness of security policies and controls is a fundamental activity
that allows an agency 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.
Such testing and evaluation helps provide a more complete picture of
agencies' security postures.

DHS did not fully test and evaluate the security controls of four of the
five major systems we reviewed. For example, the Transportation Security
Administration did not test and evaluate security controls and policies
for a major application and general support system. Further, Immigration
and Customs Enforcement did not have final test and evaluation reports for
a major application and general support system. Although we did not obtain
the test and evaluation report for US-VISIT, the information security plan
identified that comprehensive testing had not occurred for one major
application. Specifically, the application owner did not conduct systems
integration testing in the program's actual operating environment to test
such things as connectivity with other systems and networks. In its fiscal
year 2004 FISMA report, DHS identified that 24 percent of its systems had
not undergone test and evaluation. Without adequately testing and
evaluating systems, the department cannot be assured that security
controls are in place and functioning correctly to protect its information
and information systems.

Remedial Action Plans	FISMA requires each agency to develop a process for
planning, implementing, evaluating, and documenting remedial action plans,
referred to as plans of action and milestones by OMB, to address any
deficiencies in the information security policies, procedures, and
practices. The CIO is to manage the process for the agencies and be
regularly updated by program officials on their progress in implementing
remedial actions. This process allows both the CIO and the OIG to monitor
departmentwide progress, identify problems, and provide accurate
reporting. In its guidance for

annual reporting, OMB asks the agency IGs to report on the status of the
plans of action and milestones at their agencies. IGs were asked to
evaluate the process based on several criteria, including whether systems
plans are tied directly to the system budget request through the
information technology business case, as required by OMB.

For four of the five systems that we reviewed, program officials either
did not identify any resources in their plans of action and milestones
submissions, as required by OMB, to correct or mitigate identified
information security weaknesses or had not prepared plans of action and
milestones. As part of its fiscal year 2004 FISMA evaluation, the OIG
reported that DHS's plans of action and milestones process was not
adequate. Specifically, the estimated funding necessary to correct or
mitigate information security weaknesses was not identified in the
components' plans of action and milestones submissions, system-level plans
of action and milestones were not linked to individual components' budget
submissions, and not all of the components were capturing information
security weaknesses from all sources for reporting on their plans of
action and milestones. We found that a major application at Immigration
and Customs Enforcement and a general support system at Emergency
Preparedness and Response had not allocated any funds to correct
specifically identified weaknesses. Although some actions did not have an
associated cost, there were instances where it was apparent that costs
would be incurred for the corrective action. Further, the Transportation
Security Administration did not prepare plans of action and milestones for
information security weaknesses associated with a major application and
general support system. As a result, DHS does not have assurance that all
information security weaknesses have been reported and that corrective
actions will appropriately be taken to address the weaknesses.

Continuity of Operations	Continuity of operations plans provide specific
instructions for restoring critical systems, including such elements as
arrangement for alternative processing facilities in case the usual
facilities are significantly damaged or cannot be accessed due to
unexpected events. These events may include such things as temporary power
failure, accidental loss of files, or a major disaster. It is important
that these plans be clearly documented, communicated to potentially
affected staff, and updated to reflect current operations. According to
NIST guidance, continuity planning includes establishing thorough plans,
procedures, and technical measures that can enable a system to be
recovered quickly and effectively following a service disruption or
disaster. Further, the testing of continuity of operations plans

is essential to determining whether plans will function as intended in an
emergency situation.

For all five of the continuity of operations plans reviewed, program
officials either did not include all information necessary to restore
operations in the event of a disaster or have a documented plan. For
example, the continuity of operations plans for an Immigration and Customs
Enforcement general support system and a major application lacked critical
information such as the activities necessary to return to normal
operations, personnel contact information, locations of associated
telecommunications infrastructure, location of off-site storage for backup
media, and vendor contact information. Further, program officials did not
have continuity of operations plans for a Transportation Security
Administration major application and general support system. The OIG also
reported deficiencies in DHS's continuity of operations plans.
Specifically, the OIG performed a quality review of selected certification
and accreditation packages and found instances where continuity of
operations plans did not meet all of the applicable requirements. Further,
the OIG identified instances in which systems were accredited even though
continuity of operations plans had not been developed or tested. Moreover,
in its FISMA report to OMB for fiscal year 2004, DHS had reported that 79
percent of its systems did not have a tested continuity of operations
plan. As a result, the department has limited assurance that it will be
able to protect its critical and sensitive information and information
systems and resume operations promptly when unexpected events or unplanned
interruptions occur.

DHS Does Not Have a Complete FISMA requires agencies to develop, maintain,
and annually update an

and Accurate Information inventory of information systems that are either
operated by the agency or

Systems Inventory 	under its control. The inventory is to identify the
interfaces between each system and all the other systems or networks with
which it communicates, including those that are not operated by or under
the control of DHS.

In December 2004, the DHS CISO approved a departmentwide information
systems inventory methodology that its contractor developed and has begun
implementing it across the department. Our assessment of the methodology
determined that it is appropriately based on the requirements of FISMA,
OMB policies, and applicable NIST guidance and standards and, if fully
implemented, could provide the department with a comprehensive inventory
of its information systems.

As of March 2005, DHS has completed the information systems inventory for
the OIG and the Transportation Security Administration and is completing
its efforts to implement the methodology at the Immigration and Customs
Enforcement. In response to the OIG's fiscal year 2004 FISMA report, which
reiterated its prior year recommendation that DHS develop a complete and
accurate systems inventory, DHS acknowledged that it needs a complete and
accurate systems inventory for all of its components in order to
effectively manage its program and ensure departmentwide implementation.
Subsequent to that report, DHS established a milestone of August 5, 2005,
for developing a complete DHS systems inventory. Until DHS has a complete
and accurate systems inventory, DHS will be inhibited in its ability to
oversee and manage the information and information systems that support
the operations and assets of the agency.

    Management Oversight Needs Improvement

Shortfalls in executing the responsibilities for ensuring compliance with
the departmentwide information security program allowed the weaknesses
that we identified to occur. The CISO has responsibility for overseeing
DHS components' compliance with key information security practices and
controls. To fulfill this responsibility, the CISO developed and
implemented Trusted Agent FISMA14 in order to aggregate the component's
reported performance data that arise from annual self-assessments and OMB
metrics for key information security activities, such as number of
significant deficiencies and whether remedial action plans to address the
deficiencies had been developed, and the number of system continuity of
operations plans documented and tested. Security officers at the
components are responsible for updating the tool with data that arise from
annual self-assessments, as well as from other system-level security
metrics. The security managers have the responsibility for ensuring that
all required metrics data are updated. These data are aggregated in the
digital dashboard15 and reported to OMB for the department as a whole.

14Trusted Agent FISMA is an enterprise tool for aggregating data reported
by the components to gauge how well the department is complying with key
information security practices and controls.

15The digital dashboard is to serve as a management tool to ensure the
components take a risk-based, cost-effective approach to secure their
information and information systems, identify and resolve current
information security weaknesses and risks, as well as protect against
future vulnerabilities and threats. The dashboard allows management to
monitor the components' remediation efforts to identify progress and
problems. Each component's success in meeting the FISMA requirements is
reported as a percentage of compliance, along with a red, amber, or green
color-coded gauge or traffic light display.

However, the OIG identified that DHS could not rely on the accuracy and
completeness of the data contained in Trusted Agent FISMA, which
contributed to the OIG's overall recommendation that DHS continue to
consider its information security program a significant deficiency for
fiscal year 2004. Examples of the weaknesses that they identified include

o 	significant weaknesses were not consistently reported or linked to
plans of action and milestones;

o 	plans of action and milestones that have been identified and documented
included some that were neither current nor updated periodically;

o 	some data fields, such as the "Scheduled Completion Date," for plans of
action and milestones that could be arbitrarily revised by the components
with no audit trail to monitor such activity; and

o  information entered by the components was not verified.

Unless the data being collected and tracked from the components are
reliable, the CISO has no assurance that the components' metrics
accurately reflect the status of their implementation of key information
security activities. Having reliable metrics on key activities such as
those we identified as having weaknesses-risk assessments, security plans,
security test and evaluation, remedial action plans, and continuity of
operations plans-is critical. According to DHS's information security
policies and procedures, the CISO is to use these metrics to validate the
efficacy of the program, identify gaps between reported and actual
performance data, and help focus attention on presidential, congressional,
or department priorities. In response to the OIG's FISMA evaluation, the
CIO stated that the department had recently initiated a project to review
and verify the metrics data. However, the CIO has not established a
milestone for completing this project. Implementing a process for
verifying the reported data could help improve the quality of the
information used by the CISO to oversee the components' compliance with
the departmentwide information security program.

Conclusions	DHS has not fully implemented a comprehensive, departmentwide
information security program, thereby jeopardizing the confidentiality,
integrity, and availability of the information and information systems
that it relies on to accomplish its mission. DHS's efforts to date in
developing and

documenting such a program has merit. However, ensuring that the
components implement key information security practices and controls,
especially with a department as diverse as DHS, requires effective
management oversight and monitoring. Having a complete and accurate
information systems inventory and a process in place to verify the
components' data on their implementation of the key information security
practices and controls is needed for DHS to effectively implement its
information security program. However, until it does so, DHS will have
limited assurance that its operations and assets are adequately protected.

Recommendations for 	To help fully implement DHS's departmentwide
information security program, we recommend that the Secretary of DHS
direct the Chief

  Executive Action Information Officer to

o 	instruct the CISO and component agencies to fully implement the
following key information security practices and controls by

o   o   o   o   o

developing complete risk assessments;
documenting comprehensive security plans;
fully performing testing and evaluation of security controls;
reporting complete remedial action plans; and
developing, documenting, and testing continuity of operations plans.

o 	establish milestones for completing verification of the components'
reported performance data in Trusted Agent FISMA.

Agency Comments	In providing written comments on a draft of this report,
DHS's Chief Information Security Officer generally agreed with the
contents of the report and described recently completed, ongoing or
planned efforts to implement the department's information security
program. For example, the Chief Information Security Officer stated that
the agency has efforts under way to improve processes for developing
complete risk assessments; documenting and updating security plans;
verifying the results of annual testing and evaluation of security
controls; reporting complete remedial action plans; and developing,
documenting, and testing continuity of

operations plans. The Chief Information Security Officer also stated that
enhancements have been made to the Trusted Agent FISMA tool in order to
improve the reliability of the components' reported performance data.
DHS's comments are reprinted in appendix II of this report.

As agreed with your offices, unless you publicly announce its contents
earlier, we will not distribute this report further until 30 days from the
report date. At that time, we will send copies to interested congressional
committees, the DHS Secretary and, upon their request, to other interested
parties. In addition, the report will be made available at no charge on
the GAO Web site at http://www.gao.gov.

If you have any questions about this report, please contact me at (202)
5126244 or via e-mail at [email protected]. Contact points for our
Offices of Congressional Relations and Public Affairs may be found on the
last page of this report. Key contributors to this report are acknowledged
in appendix III.

Sincerely yours,

Gregory C. Wilshusen Director, Information Security Issues

Appendix I

Scope and Methodology

To determine whether the Department of Homeland Security (DHS) had
developed and documented a departmentwide information security program, we
reviewed departmental information security plans, policies, procedures,
and handbooks; agencywide tools for aggregating the components'
performance data on their assessment of meeting the requirements of the
Federal Information Security Management Act of 2002 (FISMA); and DHS's
information systems inventory methodology. We assessed whether DHS's
departmentwide information security program was consistent with the
requirements of FISMA and applicable Office of Management and Budget (OMB)
policies1 and NIST guidance related to performing risk assessments,
developing information security plans, testing and evaluating security
controls, documenting remedial action plans, and documenting and testing
continuity of operations plans.

To determine whether DHS had implemented its departmentwide information
security program, we focused our review on the components' alignment with
key information security practices and controls. To accomplish this, we
selected seven DHS components-five of which DHS categorize as major agency
components due to their size and mission. The five components selected
were: Customs and Border Protection, Transportation Security
Administration, Immigration and Customs Enforcement, U.S. Coast Guard, and
Emergency Preparedness and Response. We also selected these five
components because they had been in existence prior to the transformation
of DHS and, from an evaluation standpoint, focused on determining their
progress in aligning with and implementing the departmentwide information
security program given these components had their own information
technology management structures, information security policies and
practices, and infrastructures. As a comparison, we selected one
component-Science and Technology- that had not existed prior to the
transformation to evaluate its alignment with and implementation of the
departmentwide information security program. We also selected the United
States Visitor and Immigrant Status Indicator Technology (US-VISIT)
program due to its significant mission in providing security to our
nation's borders.

Based on their criticality to DHS's mission operations, we selected for
review three major applications and three general support systems and
obtained documentation contained in the certification and accreditation

1Office of Management and Budget, Circular A-130, Appendix III, Security
of Federal Automated Information Resources (Washington, D.C.: Nov. 28,
2000).

Appendix I Scope and Methodology

packages for the selected systems to assess the extent to which the
components implemented key information security practices and controls.
Certification is a comprehensive process of assessing the level of
security risk, identifying security controls needed to reduce risk and
maintain it at an acceptable level, documenting security controls in a
security plan, and testing controls to ensure they operate as intended.
Accreditation is a written decision by an agency management official
authorizing operation of a particular information system or group of
systems. Specifically, we reviewed and analyzed information security
plans, risk assessments, information security test and evaluation reports,
remedial action plans, and continuity of operations plans for the selected
systems. We compared the components' documented practices and controls for
these information security areas with applicable FISMA requirements, OMB
guidance, and applicable NIST guidance.

To supplement our documentation reviews and analysis, we reviewed and
considered various audit reports from the CIO and OIG evaluations of DHS's
information security program, including DHS's and OIG's annual FISMA
reports from 2003 and 2004.

We performed our review at DHS headquarters, the offices of the seven
components, and at our headquarters in the Washington, D.C., metropolitan
area; and at DHS's network and security operations center in Denver,
Colorado, from July 2004 through May 2005. Our review was performed in
accordance with generally accepted government auditing standards.

Appendix II

Comments from the Department of Homeland Security

Appendix II Comments from the Department of Homeland Security Appendix II
Comments from the Department of Homeland Security Appendix II Comments
from the Department of Homeland Security Appendix II Comments from the
Department of Homeland Security Appendix II Comments from the Department
of Homeland Security

Appendix III

                     GAO Contact and Staff Acknowledgments

GAO Contact Gregory C. Wilshusen, (202) 512-6244

Staff 	In addition to the individual named above, Jenniffer Wilson,
Assistant Director; Joanne Fiorino; Kenneth A. Johnson; Lori Martinez;
Leena

Acknowledgments Mathew; and Altony Rice made key contributions to this
report.

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