Information Security: Further Efforts Needed to Address
Significant Weaknesses at the Internal Revenue Service
(30-MAR-07, GAO-07-364).
In fiscal year 2006, the Internal Revenue Service (IRS) collected
about $2.5 trillion in tax payments and paid about $277 billion
in refunds. Because IRS relies extensively on computerized
systems, effective information security controls are essential to
ensuring that financial and taxpayer information is adequately
protected from inadvertent or deliberate misuse, fraudulent use,
improper disclosure, or destruction. As part of its audit of
IRS's fiscal years 2006 and 2005 financial statements, GAO
assessed (1) IRS's actions to correct previously reported
information security weaknesses and (2) whether controls were
effective in ensuring the confidentiality, integrity, and
availability of financial and sensitive taxpayer information. To
do this, GAO examined IRS information security policies and
procedures, guidance, security plans, reports, and other
documents; tested controls over five critical applications at
three IRS sites; and interviewed key security representatives and
management officials.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-07-364
ACCNO: A67589
TITLE: Information Security: Further Efforts Needed to Address
Significant Weaknesses at the Internal Revenue Service
DATE: 03/30/2007
SUBJECT: Computer security
Confidential information
Data integrity
Information security
Internal controls
Physical security
Program evaluation
Risk assessment
Risk management
Servers
Tax administration systems
Tax information confidentiality
Program implementation
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GAO-07-364
* [1]Results in Brief
* [2]Background
* [3]Objectives, Scope, and Methodology
* [4]IRS Made Limited Progress in Correcting Previously Reported
* [5]Significant Weaknesses Continue to Place Financial and Taxpa
* [6]Access Controls Were Inadequate
* [7]User Identification and Authentication
* [8]Authorization
* [9]Cryptography
* [10]Audit and Monitoring
* [11]Physical Security
* [12]Other Information System Controls Were Not Sufficient
* [13]Configuration Management
* [14]Segregation of Duties
* [15]Media Destruction and Disposal
* [16]Personnel Security
* [17]Agencywide Information Security Program Was Not Yet Fully Im
* [18]Risk Assessments
* [19]Policies and Procedures
* [20]Security Plans
* [21]Specialized Training
* [22]Tests and Evaluations of Control Effectiveness
* [23]Remedial Actions
* [24]Continuity of Operations
* [25]Conclusions
* [26]Recommendations for Executive Action
* [27]Agency Comments
* [28]GAO Contacts
* [29]Staff Acknowledgments
* [30]GAO's Mission
* [31]Obtaining Copies of GAO Reports and Testimony
* [32]Order by Mail or Phone
* [33]To Report Fraud, Waste, and Abuse in Federal Programs
* [34]Congressional Relations
* [35]Public Affairs
Report to the Commissioner of Internal Revenue
United States Government Accountability Office
GAO
March 2007
INFORMATION SECURITY
Further Efforts Needed to Address Significant Weaknesses at the Internal
Revenue Service
GAO-07-364
Contents
Letter 1
Results in Brief 2
Background 3
Objectives, Scope, and Methodology 5
IRS Made Limited Progress in Correcting Previously Reported Weaknesses 7
Significant Weaknesses Continue to Place Financial and Taxpayer
Information at Risk 8
Conclusions 22
Recommendations for Executive Action 22
Agency Comments 23
Appendix I Comments from the Commissioner of Internal Revenue 26
Appendix II GAO Contacts and Staff Acknowledgments 29
Abbreviations
CIO Chief Information Officer
FISMA Federal Information Security Management Act
IRS Internal Revenue Service
MA&SS Mission Assurance and Security Services
NIST National Institute of Standards and Technology
OMB Office of Management and Budget
TIGTA Treasury Inspector General for Tax Administration
This is a work of the U.S. government and is not subject to copyright
protection in the United States. It may be reproduced and distributed in
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separately.
United States Government Accountability Office
Washington, DC 20548
March 30, 2007
The Honorable Mark W. Everson
Commissioner of Internal Revenue
Dear Commissioner Everson:
The Internal Revenue Service (IRS) has a demanding responsibility in
collecting taxes, processing tax returns, and enforcing the nation's tax
laws. It relies extensively on computerized systems to support its
financial and mission-related operations. Effective information system
controls are essential to ensuring that financial and taxpayer information
are adequately protected from inadvertent or deliberate misuse, fraudulent
use, improper disclosure, or destruction. These controls also affect the
confidentiality, integrity, and availability of financial and sensitive
taxpayer information.
As part of our audit of IRS's fiscal years 2006 and 2005 financial
statements, we assessed the effectiveness of the service's information
security controls^1 over key financial systems, information, and
interconnected networks at three locations. These systems support the
processing, storage, and transmission of financial and sensitive taxpayer
information. In our report on IRS's fiscal years 2006 and 2005 financial
statements,^2 we reported that the new information security deficiencies
we identified in fiscal year 2006 and the unresolved deficiencies from
prior audits represent a material weakness^3 in internal controls over
financial and tax processing systems.
^1Information security controls include electronic access controls,
software change controls, physical security, segregation of duties, and
continuity of operations. These controls are designed to ensure that
access to data is appropriately restricted, that only authorized changes
to computer programs are made, that physical access to sensitive computing
resources and facilities is protected, that computer security duties are
segregated, and that back-up and recovery plans are adequate to ensure the
continuity of essential operations.
^2GAO, Financial Audit: IRS's Fiscal Years 2006 and 2005 Financial
Statements, [36]GAO-07-136 (Washington, D.C.: Nov. 9, 2006).
^3A material weakness is a reportable condition that precludes the
entity's internal controls from providing reasonable assurance that
material misstatements in the financial statements would be prevented or
detected on a timely basis.
We assessed (1) the status of IRS's actions to correct or mitigate
previously reported information security weaknesses at two data processing
sites and (2) whether controls over key financial and tax processing
systems are effective in ensuring the confidentiality, integrity, and
availability of financial and sensitive taxpayer information.
This report provides a general summary of the vulnerabilities identified
and our recommendations to help strengthen and improve IRS's information
security program. We are also issuing a separate report for limited
distribution that contains sensitive information. It describes in more
detail the information security weaknesses that we identified and our
specific recommendations for correcting them.
We performed our review in accordance with generally accepted government
auditing standards, from June 2006 through November 2006.
Results in Brief
IRS has made limited progress toward correcting previously reported
information security weaknesses at two data processing sites. It has
corrected or mitigated 25 of the 73 information security weaknesses that
we reported as unresolved at the time of our last review at those sites.
Actions have been taken to address weaknesses related to access controls
and configuration management, among other things. For example, IRS has
implemented controls used to authorize access to Windows systems, network
devices,^4 databases, and mainframe systems; improved password controls on
its servers; enhanced audit and monitoring efforts for mainframe and
Windows user activity; conducted a facility risk assessment at a critical
data processing site; and improved change controls over one of its
mainframe systems. Nevertheless, 66 percent, or 48 of the 73 previously
identified information security weaknesses remain unresolved.
Significant weaknesses in access controls and other information security
controls continue to threaten the confidentiality, integrity, and
availability of IRS's financial and tax processing systems and
information. IRS has not consistently implemented effective access
controls to prevent, limit, or detect unauthorized access to computing
resources from within its internal network. These access controls include
those related to user identification and authentication, authorization,
cryptography, audit and monitoring, and physical security. In addition,
IRS faces risks to its financial and sensitive taxpayer information due to
weaknesses in configuration management, segregation of duties, media
destruction and disposal, and personnel security controls. A key reason
for the information security weaknesses in IRS's financial and tax
processing systems is that it has not yet fully implemented its agencywide
information security program to ensure that controls are effectively
established and maintained. As a result, weaknesses in information
security controls over its key financial and tax processing systems could
impair IRS's ability to perform vital functions and could increase the
risk of unauthorized disclosure, modification, or destruction of financial
and sensitive taxpayer information.
^4Organizations secure their networks, in part, by installing and
configuring network devices that permit authorized network service
requests, deny unauthorized requests, and limit the services that are
available on the network. Devices used to secure networks include (1)
firewalls that prevent unauthorized access to the network, (2) routers
that filter and forward data along the network, (3) switches that forward
information among segments of a network, and (4) servers that host
applications and data.
We are making recommendations to the Commissioner of Internal Revenue to
take several actions to fully implement a comprehensive agencywide
information security program. We also are making recommendations to the
commissioner in a separate report with limited distribution. These
recommendations consist of actions to be taken to correct the specific
information security weaknesses related to user identification and
authentication, authorization, cryptography, audit and monitoring,
physical security, configuration management, segregation of duties, media
destruction and disposal, and personnel security.
In providing written comments on a draft of this report, the Commissioner
of Internal Revenue recognized that continued diligence of IRS's security
and privacy responsibilities is required. He further stated that IRS would
continue to remedy all recommendations to completion to ensure that
operations of its applications and systems adhere to security
requirements.
Background
Information security is a critical consideration for any organization that
depends on information systems and computer networks to carry out its
mission or business. It is especially important for government agencies,
where 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, systems are
unprotected from individuals and groups with malicious intent who can
intrude and use their access to obtain sensitive information, commit
fraud, disrupt operations, or launch attacks against other computer
systems and networks. 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, and steady advances in the
sophistication and effectiveness of attack technology.
Our previous reports, and those by the Treasury Inspector General for Tax
Administration (TIGTA), describe persistent information security
weaknesses that place federal agencies, including IRS, at risk of
disruption, fraud, or inappropriate disclosure of sensitive information.
Recognizing the importance of securing federal agencies' information
systems, Congress enacted the Federal Information Security Management Act
(FISMA) in December 2002^5 to strengthen the security of information and
systems within federal agencies. FISMA 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. Such a program includes developing and
implementing security plans, policies, and procedures; testing and
evaluating the effectiveness of controls; assessing risk; providing
specialized training; planning, implementing, evaluating, and documenting
remedial action to address information security deficiencies; and ensuring
continuity of operations. We have designated information security as a
governmentwide high-risk area since 1997^6--a designation that remains in
force today.^7
IRS has demanding responsibilities in collecting taxes, processing tax
returns, and enforcing the nation's tax laws. It relies extensively on
computerized systems to support its financial and mission-related
operations. In fiscal year 2006, IRS collected about $2.5 trillion in tax
payments, processed hundreds of millions of tax and information returns,
and paid about $277 billion in refunds to taxpayers. IRS is a large and
complex organization, adding unique mission operational challenges for
management. It employs tens of thousands of people in 10 service center
campuses, 3 computing centers, and numerous other field offices throughout
the United States.
^5FISMA was enacted as title III, E-Government Act of 2002, Pub. L. No.
107-347, 116 Stat. 2946 (Dec. 17, 2002).
^6GAO, High-Risk Series: Information Management and Technology,
[37]GAO/HR-97-9 (Washington, D.C.: February 1997).
^7GAO, High-Risk Series: An Update, [38]GAO-07-310 (Washington, D.C.:
January 2007).
IRS also collects and maintains a significant amount of personal and
financial information on each American taxpayer. The confidentiality of
this sensitive information must be protected; otherwise, taxpayers could
be exposed to loss of privacy and to financial loss and damages resulting
from identity theft or other financial crimes.
The Commissioner of Internal Revenue has overall responsibility for
ensuring the confidentiality, availability, and integrity of the
information and information systems that support the agency and its
operations. FISMA states that the Chief Information Officer (CIO) is
responsible for developing and maintaining an information security
program. Within IRS, this responsibility is delegated to the Chief of
Mission Assurance and Security Services (MA&SS). The Chief of MA&SS is
responsible for developing policies and procedures regarding information
technology security; establishing a security awareness and training
program; conducting security audits; coordinating the implementation of
logical access controls into IRS systems and applications; providing
physical and personnel security; and, among other things, monitoring IRS
security activities. To help accomplish these goals, MA&SS has developed
and published information security policies, guidelines, standards, and
procedures in the Internal Revenue Manual, the Law Enforcement Manual, and
other documents. The Modernization and Information Technology Services
organization, led by the CIO, is responsible for developing security
controls for systems and applications; conducting annual tests of systems;
implementing, testing, and validating the effectiveness of remedial
actions; ensuring that continuity of operations requirements are addressed
for all applications and systems it owns; and mitigating technical
vulnerabilities and validating the mitigation strategy.
Objectives, Scope, and Methodology
The objectives of our review were to determine (1) the status of IRS's
actions to correct or mitigate previously reported weaknesses at two data
processing sites and (2) whether controls over key financial and tax
processing systems located at three sites were effective in ensuring the
confidentiality, integrity, and availability of financial and sensitive
taxpayer information. This review was completed to support the annual
financial statement audit, by assessing the effectiveness of information
system controls for the purposes of supporting our opinion on internal
controls over the preparation of the financial statements.
We concentrated our evaluation primarily on threats emanating from sources
internal to IRS's computer networks. Our evaluation was based on (1) our
Federal Information System Controls Audit Manual, which contains guidance
for reviewing information system controls that affect the confidentiality,
integrity, and availability of computerized information; (2) FISMA, which
establishes key elements that are required for an effective agencywide
information security program; and (3) previous reports from TIGTA and GAO.
Specifically, we evaluated information security controls that are intended
to
o prevent, limit, and detect electronic access to computer
resources (information, programs, and systems), thereby protecting
these resources against unauthorized disclosure, modification, and
use;
o provide physical protection of computer facilities and resources
from espionage, sabotage, damage, and theft;
o prevent the exploitation of security vulnerabilities;
o prevent the introduction of unauthorized changes to application
or system software;
o ensure that work responsibilities for computer functions are
segregated so that one individual does not perform or control all
key aspects of computer-related operations and, thereby, have the
ability to conduct unauthorized actions or gain unauthorized
access to assets or records without detection;
o provide confidentiality of used media; and
o limit the disruption to a system due to the intentional or
unintentional actions of individuals.
In addition, we evaluated IRS's agencywide information security
program. We identified and reviewed pertinent IRS information
security policies and procedures, guidance, security plans,
relevant reports, and other documents. We also tested the
effectiveness of information security controls at three IRS sites.
We focused on five critical applications that directly or
indirectly support the processing of material transactions that
are reflected in the agency's financial statement. These
applications are used for procurement, asset management, and tax
administration, which are located at the sites. We also discussed
with key security representatives and management officials whether
information security controls were in place, adequately designed,
and operating effectively.
IRS Made Limited Progress in Correcting Previously Reported
Weaknesses
IRS has made limited progress toward correcting previously
reported information security weaknesses at two data processing
sites. Specifically, it has corrected or mitigated 25 of the 73
weaknesses that we reported as unresolved at the time of our last
review. IRS corrected weaknesses related to access controls and
configuration management, among others. For example, it has
o made progress in implementing controls used to authorize access
to Windows systems, network devices, databases, and mainframe
systems by, among other things, removing administrative privileges
from Windows users who did not need them to perform job duties;
securely configuring the protocol used for managing network
performance; improving control over data sharing among mainframe
users; and restricting a certain access privilege to mainframe
users who did not need it to perform their job duties;
o improved password controls on its servers by installing a
password filter on Windows systems requiring users to create
passwords in accordance with IRS policy, discontinuing the use of
stored passwords in clear text for automatic logon files and
structured query language scripts, and requiring password
complexity and stronger password expiration policies on Windows
systems;
o enhanced audit and monitoring efforts for mainframe and Windows
user activity;
o conducted a facility risk assessment at a critical data
processing site; and
o improved change controls over one of IRS's mainframe systems.
In addition, IRS has made progress in enhancing its information
security program. For example, IRS has trained its staff to
restore operations in the event of an emergency at an off-site
location, assessed risks for the systems we reviewed, certified
and accredited the systems we reviewed, enhanced information
security awareness and training by providing training to employees
and contractors, and established an ongoing process of testing and
evaluating its systems to ensure compliance with policies and
procedures.
Although IRS has made progress in correcting many of the
previously identified security weaknesses, 48 weaknesses (66
percent) remain unresolved. For example, IRS continued to, among
other things,
o use inadequate account lockout settings for Windows servers,
o improperly restrict file permissions on UNIX systems,
o routinely permit unencrypted protocols for remote logon
capability to servers,
o insufficiently monitor system activities and configure certain
servers to ensure adequate audit trails,
o inadequately verify employees' identities against official IRS
photo identification,
o use an ineffective patch management program, and
o use disaster recovery plans that did not include disaster
recovery procedures for certain mission-critical systems.
Significant Weaknesses Continue to Place Financial and Taxpayer
Information at Risk
Significant weaknesses in access controls and other information
security controls continue to threaten the confidentiality,
integrity, and availability of IRS's financial and tax processing
systems and information. A primary reason for these weaknesses is
that IRS has not yet fully implemented its information security
program. As a result, IRS's ability to perform vital functions
could be impaired and the risk of unauthorized disclosure,
modification, or destruction of financial and sensitive taxpayer
information is increased.
Access Controls Were Inadequate
A basic management objective for any organization is to protect
the resources that support its critical operations from
unauthorized access. Organizations accomplish this objective by
designing and implementing controls that are intended to prevent,
limit, and detect unauthorized access to computing resources,
programs, information, and facilities. Inadequate access controls
diminish the reliability of computerized information and increase
the risk of unauthorized disclosure, modification, and destruction
of sensitive information and disruption of service. Access
controls include those related to user identification and
authentication, authorization, cryptography, audit and monitoring,
and physical security. IRS did not ensure that it consistently
implemented effective access controls in each of these areas, as
the following sections in this report demonstrate.
User Identification and Authentication
A computer system must be able to identify and authenticate
different users so that activities on the system can be linked to
specific individuals. When an organization assigns unique user
accounts to specific users, the system is able to distinguish one
user from another--a process called identification. The system
also must establish the validity of a user's claimed identity by
requesting some kind of information, such as a password, that is
known only by the user--a process known as authentication.
According to IRS policy, user accounts will be associated with
only one individual or process and should automatically lockout
after three consecutive failed logon attempts. If user accounts
are not associated with an individual (e.g., group user accounts),
they must be controlled, audited, and managed. In addition, IRS
policy requires strong enforcement of passwords for authentication
to IRS systems. For example, passwords are to expire and are not
to be shared by users.
IRS did not adequately control the identification and
authentication of users to ensure that only authorized individuals
were granted access to its systems. For example, administrators at
one site shared logon accounts and passwords when accessing a
database production server for the procurement system.^8 By
allowing users to share accounts and passwords, individual
accountability for authorized system activity as well as
unauthorized system activity could be lost. In addition, at the
same site, IRS did not enforce strong password management on the
same database production server. Accounts did not lock out users
after failed logon attempts and passwords did not expire. As a
result, the database was susceptible to a brute force password
attack that could result in unauthorized access. Furthermore, at
another site, IRS stored user IDs and passwords in mainframe files
that could be read by every mainframe user. As a result, increased
risk exists that an intruder or unauthorized user could read and
use these IDs and passwords to log on to the computer systems and
masquerade as an authorized user.
Authorization
Authorization is the process of granting or denying access rights
and permissions to a protected resource, such as a network, a
system, an application, a function, or a file. A key component of
granting or denying access rights is the concept of "least
privilege." Least privilege is a basic principle for securing
computer resources and information. This principle means that
users are granted only those access rights and permissions that
they need to perform their official duties. To restrict legitimate
users' access to only those programs and files that they need to
do their work, organizations establish access rights and
permissions. "User rights" are allowable actions that can be
assigned to users or to groups of users. File and directory
permissions are rules that regulate which users can access a
particular file or directory and the extent of that access. To
avoid unintentionally authorizing users access to sensitive files
and directories, an organization must give careful consideration
to its assignment of rights and permissions. IRS policy requires
that all production systems be securely configured to specifically
limit access privileges to only those individuals who need them to
perform their official duties.
IRS permitted excessive access to key financial systems by
granting rights and permissions that gave users more access than
they needed to perform their official duties. For example, at one
site, excessive read access was allowed to production system
libraries that contained mainframe configuration information. In
addition, this site did not maintain documentation of approved
access privileges allowed to each system resource by each user
group. Without such documentation, IRS limits its ability to
monitor and verify user access privileges. Furthermore, IRS did
not appropriately restrict the use of anonymous e-mails on the two
mainframe systems we reviewed. These servers allowed anonymous
e-mails from one of our analysts masquerading as a legitimate
sender and could expose IRS employees to malicious activity,
including phishing.^9 At another site, IRS granted all users
excessive privileges to sensitive files on its production database
server for the procurement system. Additionally, the procurement
system was vulnerable to a well-known exploit whereby database
commands could be inserted into the application through a user
input screen that was available to everyone on the agency's
network. Administrative privileges also were granted to the
procurement system's database application user ID at this
location. This user ID allowed extensive administrative privileges
that were inappropriate for this type of account. Excessive or
unauthorized access privileges provide opportunities for
individuals to circumvent security controls.
Cryptography
Cryptography^10 underlies many of the mechanisms used to enforce
the confidentiality and integrity of critical and sensitive
information. A basic element of cryptography is encryption.
Encryption can be used to provide basic data confidentiality and
integrity, by transforming plain text into cipher text using a
special value known as a key and a mathematical process known as
an algorithm. IRS policy requires the use of encryption for
transferring sensitive but unclassified information between IRS
facilities. The National Security Agency also recommends disabling
protocols that do not encrypt information transmitted across the
network, such as user ID and password combinations.
IRS did not consistently apply encryption to protect sensitive
data traversing its network. For example, at one site, IRS was
using an unencrypted protocol to manage network devices on a local
server. In addition, the procurement application and the UNIX
servers we reviewed at another site were using unencrypted
protocols. Therefore, all information, including user ID and
password information, was being sent across the network in clear
text. These weaknesses could allow an attacker to view information
and use that knowledge to gain access to financial and system data
being transmitted over the network.
Audit and Monitoring
To establish individual accountability, monitor compliance with
security policies, and investigate security violations, it is
crucial to determine what, when, and by whom specific actions have
been taken on a system. Organizations accomplish this by
implementing system or security software that provides an audit
trail, or logs of system activity, that they can use to determine
the source of a transaction or attempted transaction and to
monitor users' activities. The way in which organizations
configure system or security software determines the nature and
extent of information that can be provided by the audit trail. To
be effective, organizations should configure their software to
collect and maintain audit trails that are sufficient to track
security-relevant events. The Internal Revenue Manual requires
that auditable events be captured and audit logs be used to review
what occurred after an event, for periodic reviews, and for
real-time analysis. In addition, the manual requires that audit
logs be maintained and archived in a way that allows for efficient
and effective retrieval, viewing, and analysis, and that the logs
be protected from corruption, alteration, or deletion.
IRS did not consistently audit and monitor security-relevant
system activity on its applications. According to IRS officials,
IRS did not capture auditable events for its procurement
application as a result of system performance issues. Therefore,
no audit reports were being reviewed by managers for this
application. In addition, IRS was unable to effectively monitor
activity for its administrative financial system because the
volume of the information in the log made it difficult for IRS
officials to systematically analyze targeted activities and
security-relevant events or archive logs. As a result,
unauthorized access could go undetected, and the agency's ability
to trace or recreate events in the event of a system modification
or disruption could be diminished.
Physical Security
Physical access controls are used to mitigate the risks to
systems, buildings, and supporting infrastructure related to their
physical environment and to control the entry and exit of
personnel in buildings as well as data centers containing agency
resources. Examples of physical security controls include
perimeter fencing, surveillance cameras, security guards, and
locks. Without these protections, IRS computing facilities and
resources could be exposed to espionage, sabotage, damage, and
theft. IRS policy states that only authorized personnel should
have access to IRS buildings and structures.
Although IRS has implemented physical security controls over its
information technology resources, certain weaknesses reduce the
effectiveness of these controls. For example:
o IRS did not physically protect a server containing source code
for its procurement application. The server was not located in a
secured computer room; instead, it was located in a cubicle.
o IRS did not consistently manage the use of proximity cards,
which are used to gain access to secured IRS facilities. For
example, one of the sites we visited could not account for active
proximity cards for at least 11 separated employees. At that same
site, at least 12 employees and contractors were given proximity
cards that allowed them access to a computer room, although these
individuals did not need this access to perform their official
duties.
o IRS did not always effectively secure certain restricted areas.
For example, it implemented motion detectors at one site to
release the locks on doors that lead from areas that are
accessible by the general public directly into IRS-controlled
areas. The motion detector's field of view was set wider than
necessary, so that an unauthorized individual would simply have to
wait for an authorized individual to pass by the motion detector
on the IRS-controlled side of the door to gain unauthorized access
to the IRS facility.
As a result, IRS is at increased risk of unauthorized access to
financial information and inadvertent or deliberate disruption of
procurement services.
Other Information System Controls Were Not Sufficient
In addition to access controls, other important controls should be
in place to ensure the confidentiality, integrity, and
availability of an organization's information. These controls
include policies, procedures, and techniques for securely
configuring information systems, segregating incompatible duties,
sufficiently disposing of media, and implementing personnel
security. Weaknesses in these areas increase the risk of
unauthorized use, disclosure, modification, or loss of IRS's
information and information systems.
Configuration Management
The purpose of configuration management is to establish and
maintain the integrity of an organization's work products. By
implementing configuration management, organizations can better
ensure that only authorized applications and programs are placed
into operation through establishing and maintaining baseline
configurations and monitoring changes to these configurations.
According to IRS policy, changes to baseline configurations should
be monitored and controlled. Patch management, a component of
configuration management, is an important factor in mitigating
software vulnerability risks. Proactively managing vulnerabilities
of systems will reduce or eliminate the potential for exploitation
and involves considerably less time and effort than responding
after an exploit has occurred. Up-to-date patch installation can
help diminish vulnerabilities associated with flaws in software
code. Attackers often exploit these flaws to read, modify, or
delete sensitive information; disrupt operations; or launch
attacks against other organizations' systems. According to the
National Institute of Standards and Technology (NIST), tracking
patches allows organizations to identify which patches are
installed on a system and provides confirmation that the
appropriate patches have been applied. IRS's patch management
policy also requires that patches be implemented in a timely
manner, and that critical patches are applied within 72 hours to
minimize vulnerabilities.
IRS did not properly implement configuration management
procedures. For example, IRS did not record successful changes to
baseline configurations on one of its mainframe systems, which
supports its general ledger for tax administration activities.
Without adequately logging system configuration changes, IRS
cannot adequately ensure they are properly monitored and
controlled. In addition, IRS did not effectively track or install
patches in a timely manner. For example, one IRS location did not
have a tracking process in place to ensure that up-to-date patches
have been applied on UNIX servers. Furthermore, installation of
critical patches through the configuration management process for
Windows systems was not timely. For example, critical Windows
patches released in July 2006 had not yet been applied at the time
of our review in August 2006. As a result, increased risk exists
that the integrity of IRS systems could be compromised.
Segregation of Duties
Segregation of duties refers to the policies, procedures, and
organizational structures that help ensure that no single
individual can independently control all key aspects of a process
or computer-related operation and thereby gain unauthorized access
to assets or records. Often, organizations achieve segregation of
duties by dividing responsibilities among two or more individuals
or organizational groups. This diminishes the likelihood that
errors and wrongful acts will go undetected, because the
activities of one individual or group will serve as a check on the
activities of the other. Inadequate segregation of duties
increases the risk that erroneous or fraudulent transactions could
be processed, improper program changes implemented, and computer
resources damaged or destroyed. The Internal Revenue Manual
requires that IRS divide and separate duties and responsibilities
of incompatible functions among different individuals, so that no
individual shall have all of the necessary authority and system
access to disrupt or corrupt a critical security process.
IRS did not always properly segregate incompatible duties. For
example, IRS established test accounts on a production server for
its procurement system. Test accounts are used by system
developers and are not typically found on production servers.
Allowing test accounts on production servers creates the potential
for individuals to perform incompatible functions, such as system
development and production support. Granting this type of access
to individuals who do not require it to perform their official
duties increases the risk that sensitive information or programs
could be improperly modified, disclosed, or deleted.
Media Destruction and Disposal
Media destruction and disposal is a key to ensuring
confidentiality of information. Media can include magnetic tapes,
optical disks (such as compact disks), and hard drives.
Organizations safeguard used media to ensure that the information
it contains is appropriately controlled. Improperly disposed media
can lead to the inappropriate or inadvertent disclosure of an
agency's sensitive information or the personally identifiable
information of its employees and customers. This potential
vulnerability can be mitigated by properly sanitizing the media.
According to IRS policy, all media should be sanitized prior to
disposal in such a manner that sensitive information on that media
cannot be recovered by ordinary means. The policy further requires
that IRS maintain records certifying that sanitation was
performed.
IRS did not have an appropriate process for disposing of
information stored on optical disk. According to agency officials
at one of the sites we visited, discarded optical disks were left
unattended in a hallway bin awaiting destruction by the cleaning
staff. These disks had not been sanitized, and IRS staff were
unaware if the unattended disks contained sensitive information.
Furthermore, the cleaning staff did not maintain records
certifying that the media were destroyed. As a result, IRS could
not ensure the confidentiality of potentially sensitive
information stored on optical disks marked for destruction.
Personnel Security
The greatest harm or disruption to a system comes from the
actions, both intentional and unintentional, of individuals. These
intentional and unintentional actions can be reduced through the
implementation of personnel security controls. According to NIST,
personnel security controls help organizations ensure that
individuals occupying positions of responsibility (including
third-party service providers) are trustworthy and meet
established security criteria for those positions. Organizations
should also ensure that information and information systems are
protected during and after personnel actions, such as terminations
and transfers. Organizations can decrease the risk of harm or
disruption of systems by implementing personnel security controls
associated with personnel screening and termination. Personnel
screening controls should be implemented when an individual
requires access to facilities, information, and information
systems before access is authorized. Organizations should also
implement controls for when employment is terminated, including
ceasing information system access and ensuring the return of
organizational information system-related property (e.g., ID cards
or building passes).
According to the Internal Revenue Manual, contractor employees
must complete a background investigation to be granted on-site,
staff-like access to IRS facilities. However, if a background
investigation has not been completed, individuals may not have
access to IRS sensitive areas unless they are escorted by an IRS
employee. The manual further states that managers are responsible
for identifying separated employees in order to recover IRS
assets, such as ID media. Separated employees' accounts are to be
deactivated within 1 week of an individual's departure on friendly
terms and immediately upon an individual's departure on unfriendly
terms.
IRS did not always ensure the effective implementation of its
personnel security controls. For example, at two sites, IRS
granted contractors^11 who did not have a completed background
investigation unescorted physical access to sensitive areas. In
addition, at all three sites we reviewed, IRS did not
appropriately remove application access for separated personnel.
For example, 19 individuals who had separated from IRS for periods
ranging from 3 weeks to 14 months still maintained access to
applications during our review this year. These practices increase
the risk that individuals might gain unauthorized access to IRS
resources.
Agencywide Information Security Program Was Not Yet Fully
Implemented
A key reason for the information security weaknesses in IRS's
financial and tax processing systems is that it has not yet fully
implemented its agencywide information security program to ensure
that controls are effectively established and maintained. FISMA
requires each agency to develop, document, and implement an
information security program that, among other things, includes
o periodic assessments of the risk and the magnitude of 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) cost-effectively reduce risks, (3) ensure that information
security is addressed throughout the life cycle of each system,
and (4) ensure compliance with applicable requirements;
o plans for providing adequate information security for networks,
facilities, and systems;
o security awareness training to inform personnel of information
security risks and of their responsibilities in complying with
agency policies and procedures, as well as training personnel with
significant security responsibilities for information security;
o at least annual testing and evaluation of the effectiveness of
information security policies, procedures, and practices relating
to management, operational, and technical controls of every major
information system that is identified in the agency's inventories;
o a process for planning, implementing, evaluating, and
documenting remedial action to address any deficiencies in its
information security policies, procedures, or practices; and
o plans and procedures to ensure continuity of operations for
information systems that support the operations and assets of the
agency.
Although IRS continued to make important progress in developing
and documenting a framework for its information security program,
key components of the program had not been fully or consistently
implemented.
Risk Assessments
Identifying and assessing information security risks are essential
to determining what controls are required. Moreover, by increasing
awareness of risks, these assessments can generate support for the
policies and controls that are adopted in order to help ensure
that these policies and controls operate as intended. The Office
of Management and Budget (OMB) Circular A-130, appendix III,
prescribes that risk be reassessed when significant changes are
made to computerized systems--or at least every 3 years.
Consistent with NIST guidance, IRS requires its risk assessment
process to detail the residual risk assessed and potential
threats, and to recommend corrective actions for reducing or
eliminating the vulnerabilities identified.
Although IRS had implemented a risk assessment process, it did not
always effectively evaluate potential risks for the systems we
reviewed. IRS has reassessed the risk level for each of its 264
systems and categorized them on the basis of risk. Furthermore,
the five risk assessments that we reviewed were current,
documented residual risk assessed and potential threats, and
recommended corrective actions for reducing or eliminating the
vulnerabilities they identified. However, IRS did not identify
many of the vulnerabilities in this report and did not assess the
risks associated with them. As a result, potential risks to these
systems may be unknown.
Policies and Procedures
Another key element of an effective information security program
is to develop, document, and implement risk-based policies,
procedures, and technical standards that govern security over an
agency's computing environment. If properly implemented, policies
and procedures should help reduce the risk that could come from
unauthorized access or disruption of services. Technical security
standards provide consistent implementation guidance for each
computing environment. Developing, documenting, and implementing
security policies is important because they are the primary
mechanisms 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 that the security
policies and controls should provide.
Although IRS has developed and documented information security
policies, standards, and guidelines that generally provide
appropriate guidance to personnel responsible for securing
information and information systems, it did not always provide
needed guidance on how to guard against significant mainframe
security weaknesses. For example, IRS policy lacked guidance on
how to correctly configure certain mainframe IDs used by the
operating system and certain powerful mainframe programs used to
control processing. As a result, IRS has reduced assurance that
its systems and the information they contain are sufficiently
protected.
Security Plans
An objective of system security planning is to improve the
protection of information technology resources. A system security
plan provides an overview of the system's security requirements
and describes the controls that are in place--or planned--to meet
those requirements. OMB Circular A-130 requires that agencies
develop system security plans for major applications and general
support systems, and that these plans address policies and
procedures for providing management, operational, and technical
controls.
IRS had developed system security plans for four of the five
systems we reviewed. The plans addressed policies and procedures
for providing management, operational, and technical controls.
However, IRS had not developed a system security plan for the
system that supports its general ledger for tax administration
activities. As a result, IRS cannot ensure that appropriate
controls are in place to protect this key financial system and
critical information.
Specialized Training
People are one of the weakest links in attempts to secure systems
and networks. Therefore, an important component of an information
security program is providing required training so that users
understand system security risks and their own role in
implementing related policies and controls to mitigate those
risks. IRS policy mandates that personnel with significant
security responsibilities be provided with specialized
training.^12 In addition, IRS policy requires that personnel
performing information technology security duties meet minimum
continuing professional education levels in accordance with their
roles. Specifically, personnel performing technical security roles
are required to have 24 hours of specialized training per year,
personnel performing nontechnical roles are required to have 16
hours of specialized training per year, and personnel performing
executive security roles should have 6 hours of specialized
training per year. IRS policy also requires that effective
tracking and reporting mechanisms be in place to monitor
specialized training.
Although IRS has made significant progress in providing security
personnel with job-related training and established a methodology
for identifying employees with significant security
responsibilities, in fiscal year 2006, at least 95 individuals
with significant security responsibilities did not have the
minimum number of hours of specialized training required by IRS
policy. Of those 95 individuals, 18 had not completed any training
for the last reporting year. In addition, IRS was not able to
determine whether all of its employees had met minimum continuing
professional education requirements. For example, IRS monitored
employee training through its Enterprise Learning Management
System, but the system could not differentiate between employees
who are required to have only 6 hours of training and employees
who are required to have more. Furthermore, IRS did not track all
security-related training courses taken by its employees. These
conditions increase the risk that employees and contractors may
not be aware of their security responsibilities.
Tests and Evaluations of Control Effectiveness
Another key element of an information security program is to test
and evaluate policies, procedures, and controls to determine
weather they are effective and operating as intended. 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. FISMA requires that the frequency of tests and
evaluations be based on risks and occur no less than annually. IRS
policy also requires periodic testing and evaluation of the
effectiveness of information security policies and procedures.
IRS tested and evaluated information security controls for each of
the systems we reviewed. However, these evaluations did not
address many of the vulnerabilities we have identified in this
report. For example, IRS's test and evaluation plan for its
procurement system did not include tests for password expiration,
insecure protocols, or the removal of employees' system access
after separation from the agency. As a result, IRS has limited
assurance that it has appropriately implemented controls, and it
will be less able to identify needed controls.
Remedial Actions
A remedial action plan is a key component described in FISMA. Such
a plan assists agencies in identifying, assessing, prioritizing,
and monitoring progress in correcting security weaknesses that are
found in information systems. According to IRS policy, the agency
should document weaknesses found during security assessments as
well as document any planned, implemented, and evaluated remedial
actions to correct any deficiencies. The policy further requires
that IRS track the status of resolution of all weaknesses and
verify that each weakness is corrected.
IRS has developed and implemented a remedial action process to
address deficiencies in its information security policies,
procedures, and practices, however, this remedial action process
was not working as intended. For example, the verification process
used to determine whether remedial actions were implemented was
not always effective. Of the 73 previously reported weaknesses,
IRS had indicated that it had corrected or mitigated 57 of them.
However, of those 57 weaknesses, 33 still existed at the time of
our review. In addition, IRS had identified weaknesses but did not
document them in a remedial action plan. For example, we reviewed
system self-assessments for five systems and identified at least 8
weaknesses not documented in a remedial action plan. These
weaknesses pertained to system audit trails, approval and
distribution of continuity of operations plans, and documenting
emergency procedures. TIGTA also reported that IRS was not
tracking all weaknesses found during security assessments in 2006.
As a result, increased risk exists that known vulnerabilities will
not be mitigated.
IRS did not proactively ensure that weaknesses found at one of its
facilities or on one of its systems were considered and, if
necessary, corrected at other facilities or on similar systems.
Many of the issues identified in this report were previously
reported at other locations and on similar systems. Yet, IRS had
not applied those recommendations to the facilities and systems we
reviewed this year. For example, we have been identifying
weaknesses with encryption at IRS since 1998.^13 However, IRS was
not using encryption to protect information traversing its
network. In addition, in 2002 we recommended that IRS promptly
remove system access for separated employees and verify that
system access has been removed. Nevertheless, IRS did not promptly
remove system access for separated employees.
Recognizing the need for a servicewide solution, IRS developed a
plan in October 2006 to address many of the recurring weaknesses.
This plan includes remedial actions to address various weaknesses
such as access authorization, audit and monitoring, configuration
management, and testing of technical controls. According to IRS,
the plan should be fully implemented by fiscal year 2012. However,
until IRS fully implements its plan to address recurring
weaknesses, it may not be able to adequately protect its
information and information systems from inadvertent or deliberate
misuse, fraudulent use, improper disclosure, or destruction.
Continuity of Operations
Continuity of operations planning is a critical component of
information protection. To ensure that mission-critical operations
continue, it is necessary to be able to detect, mitigate, and
recover from service disruptions while preserving access to vital
information. The elements of robust continuity of operations
planning include, among others, identifying preventative controls
(e.g., environmental controls); developing recovery strategies,
including alternative processing locations; and performing
disaster recovery exercises to test the effectiveness of
continuity of operations plans. According to NIST, systems need to
have a reasonably well-controlled operating environment, and
failures in environmental controls such as air-conditioning
systems may cause a service interruption and may damage hardware.
IRS policy mandates that an alternate processing site be
identified, and that agreements be in place when the primary
processing capabilities are unavailable. The policy further
requires that each application's recovery plan be tested on a
yearly basis.
IRS did not have adequate environmental controls at one of the
sites we visited. For example, the air-conditioning system for the
computer room that houses the procurement system could not
adequately cool down the systems in the room and was supplemented
by a portable fan. In addition, the fire extinguishers for the
same room had not had an up-to-date inspection. Without providing
adequate environmental controls, IRS is at increased risk that
critical system hardware may be damaged.
Also, IRS had established alternate processing sites for four of
the five applications we reviewed. However, it did not have an
alternate processing site for its procurement system, and it had
not tested the application's recovery plan. As a result,
unforeseen events could significantly impair IRS's ability to
fulfill its mission.
Conclusions
IRS has made important progress in correcting or mitigating
previously reported weaknesses, implementing controls over key
financial and tax processing systems, and developing and
documenting a solid framework for its agencywide information
security program. However, information security weaknesses--both
old and new--continue to impair the agency's ability to ensure the
confidentiality, integrity, and availability of financial and
sensitive taxpayer information. These deficiencies represent a
material weakness in IRS's internal controls over its financial
and tax processing systems. A key reason for these weaknesses is
that the agency has not yet fully implemented critical elements of
its agencywide information security program. Until IRS (1) fully
implements a comprehensive agencywide information security program
that includes risk assessments, enhanced policies and procedures,
security plans, training, adequate tests and evaluations, and a
continuity of operations process for all major systems and (2)
begins to address weaknesses across the service, its facilities,
computing resources, and the financial and sensitive taxpayer
information on its systems will remain vulnerable.
Recommendations for Executive Action
To help establish effective information security over key
financial and tax processing systems, financial and sensitive
taxpayer information, and interconnected networks, we recommend
that you take the following 10 actions to implement an agencywide
information security program:
o update the risk assessments for the five systems reviewed to
include the vulnerabilities identified in this report;
o update policies and procedures to include guidance on
configuring mainframe ID's used by the operating system and
certain powerful mainframe programs used to control processing;
o develop a system security plan for the system that supports the
general ledger for tax administration activities;
o enhance the Enterprise Learning Management System to include all
security-related training courses taken by IRS employees and
contractors and to differentiate required training hours for all
employees;
o update test and evaluation procedures to include tests for
vulnerabilities identified in this report, such as password
expiration, insecure protocols, and removal of system access after
separation from the agency;
o implement a revised remedial action verification process that
ensures actions are fully implemented;
o document weaknesses identified during security assessments in a
remedial action plan;
o provide adequate environmental controls for the computer room
that houses the procurement system, such as a sufficient
air-conditioning system and up-to-date fire extinguishers;
o establish an alternate processing site for the procurement
application; and
o test the procurement system recovery plan.
We are also making 50 detailed recommendations in a separate
report with limited distribution. These recommendations consist of
actions to be taken to correct the specific information security
weaknesses related to user identification and authentication,
authorization, cryptography, audit and monitoring, physical
security, configuration management, segregation of duties, media
destruction and disposal, and personnel security.
Agency Comments
In providing written comments (reprinted in app. I) on a draft of
this report, the Commissioner of Internal Revenue stated that IRS
understands that information security controls are essential for
ensuring information is adequately protected from inadvertent or
deliberate misuse, disruption, or destruction. He also noted that
IRS has taken several steps to create a strong agencywide
information security program as required by FISMA. The
commissioner recognized that continued diligence of IRS's security
and privacy responsibilities is required, and he further stated
that IRS will continue to remedy all recommendations to completion
to ensure that operations of its applications and systems adhere
to security requirements.
This report contains recommendations to you. As you know, 31
U.S.C. 720 requires the head of a federal agency to submit a
written statement of the actions taken on our recommendations to
the Senate Committee on Homeland Security and Governmental Affairs
and to the House Committee on Oversight and Government Reform not
later than 60 days from the date of the report and to the House
and Senate Committees on Appropriations with the agency's first
request for appropriations made more than 60 days after the date
of this report. Because agency personnel serve as the primary
source of information on the status of recommendations, GAO
requests that the agency also provide it with a copy of your
agency's statement of action to serve as preliminary information
on the status of open recommendations.
^8This system processed about $3.9 billion in fiscal year 2006.
^9Phishing is the act of tricking individuals into disclosing sensitive
personal information through deceptive computer-based means.
^10Cryptography is used to secure transactions by providing ways to ensure
data confidentiality, data integrity, authentication of the message's
originator, electronic certification of data, and nonrepudiation (proof of
the integrity and origin of data that can be verified by a third party).
^11This year's background investigation review only consisted of
contractors.
^12In its fiscal year 2006 FISMA submission, IRS reported that it has
2,476 employees with significant security responsibilities.
^13GAO, IRS Systems Security: Although Significant Improvements Made, Tax
Processing Operations and Data Still at Serious Risk, [45]GAO/AIMD-99-38
(Washington, D.C.: Dec. 14, 1998); and Information Security: Continued
Progress Needed to Strengthen Controls at the Internal Revenue Service,
[46]GAO-06-328 (Washington, D.C.: Mar. 23, 2006).
We are sending copies of this report to interested congressional
committees and the Secretary of the Treasury. We will also make
copies available to others upon request. In addition, this report
will be available at no charge on the GAO Web site at
http://www.gao.gov.
If you have any questions regarding this report, please contact
Gregory Wilshusen at (202) 512-6244 or Keith Rhodes at (202)
512-6412. We can also be reached by e-mail at [email protected]
and [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
listed in appendix II.
Sincerely yours,
Gregory C. Wilshusen
Director, Information Security Issues
Keith A. Rhodes, Chief Technologist
Appendix I: Comments from the Commissioner of Internal Revenue
Appendix II: GAO Contacts and Staff Acknowledgments
GAO Contacts
Gregory C. Wilshusen, (202) 512-6244 Keith A. Rhodes, (202)
512-6412
Staff Acknowledgments
In addition to the persons named above, Don Adams, Bruce Cain,
Mark Canter, Nicole Carpenter, Jason Carroll, West Coile, Denise
Fitzpatrick, Edward Glagola Jr., David Hayes, Kevin Jacobi,
Jeffrey Knott (Assistant Director), George Kovachick, Joanne
Landesman, Leena Mathew, Kevin Metcalfe, Amos Tevelow, and Chris
Warweg made key contributions to this report.
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Highlights of [49]GAO-07-364 , a report to the Commissioner of Internal
Revenue
March 2007
INFORMATION SECURITY
Further Efforts Needed to Address Significant Weaknesses at the Internal
Revenue Service
In fiscal year 2006, the Internal Revenue Service (IRS) collected about
$2.5 trillion in tax payments and paid about $277 billion in refunds.
Because IRS relies extensively on computerized systems, effective
information security controls are essential to ensuring that financial and
taxpayer information is adequately protected from inadvertent or
deliberate misuse, fraudulent use, improper disclosure, or destruction.
As part of its audit of IRS's fiscal years 2006 and 2005 financial
statements, GAO assessed (1) IRS's actions to correct previously reported
information security weaknesses and (2) whether controls were effective in
ensuring the confidentiality, integrity, and availability of financial and
sensitive taxpayer information. To do this, GAO examined IRS information
security policies and procedures, guidance, security plans, reports, and
other documents; tested controls over five critical applications at three
IRS sites; and interviewed key security representatives and management
officials.
[50]What GAO Recommends
GAO is recommending that the IRS Commissioner take several actions to
fully implement an agencywide information security program. In commenting
on a draft of this report, IRS agreed to address all recommendations.
IRS has made limited progress toward correcting or mitigating previously
reported information security weaknesses at two data processing sites, but
66 percent of the weaknesses that GAO had previously identified still
existed. Specifically, IRS has corrected or mitigated 25 of the 73
information security weaknesses that GAO reported as unresolved at the
time of our last review. For example, IRS has improved password controls
on its servers and enhanced audit and monitoring efforts for mainframe and
Windows user activity, but it continues to (1) use inadequate account
lockout settings for Windows servers and (2) inadequately verify
employees' identities against official IRS photo identification.
Significant weaknesses in access controls and other information security
controls continue to threaten the confidentiality, integrity, and
availability of IRS's financial and tax processing systems and
information. For example, IRS has not implemented effective access
controls related to user identification and authentication, authorization,
cryptography, audit and monitoring, physical security, and other
information security controls. These weaknesses could impair IRS's ability
to perform vital functions and increase the risk of unauthorized
disclosure, modification, or destruction of financial and sensitive
taxpayer information. Accordingly, GAO has reported a material weakness in
IRS's internal controls over its financial and tax processing systems.
A primary reason for the new and old weaknesses is that IRS has not yet
fully implemented its information security program. IRS has taken a number
of steps to develop, document, and implement an information security
program. However, the agency has not yet fully or consistently implemented
critical elements of its program. Until IRS fully implements an agencywide
information security program that includes risk assessments, enhanced
policies and procedures, security plans, training, adequate tests and
evaluations, and a continuity of operations process for all major systems,
the financial and sensitive taxpayer information on its systems will
remain vulnerable.
References
Visible links
36. http://www.gao.gov/cgi-bin/getrpt?GAO-07-136
37. http://www.gao.gov/cgi-bin/getrpt?GAO/HR-97-9
38. http://www.gao.gov/cgi-bin/getrpt?GAO-07-310
45. http://www.gao.gov/cgi-bin/getrpt?GAO/AIMD-99-38
46. http://www.gao.gov/cgi-bin/getrpt?GAO-06-328
49. http://www.gao.gov/cgi-bin/getrpt?GAO-07-364
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