Information Security: Homeland Security Needs to Immediately
Address Significant Weaknesses in Systems Supporting the US-VISIT
Program (13-JUL-07, GAO-07-870).
Intended to enhance the security of U.S. citizens and visitors,
United States Visitor and Immigrant Status Indicator Technology
(US-VISIT) program encompasses the pre-entry, entry, status
management, and exit of foreign national travelers who enter and
leave the United States at 285 air, sea, and land ports of entry.
GAO was asked to determine whether Department of Homeland
Security (DHS) has implemented appropriate controls to protect
the confidentiality, integrity, and availability of the
information and systems used to support the US-VISIT program. To
do this, GAO examined the controls over the systems operated by
Customs and Border Protection (CBP) that support the US-VISIT
program.
-------------------------Indexing Terms-------------------------
REPORTNUM: GAO-07-870
ACCNO: A72729
TITLE: Information Security: Homeland Security Needs to
Immediately Address Significant Weaknesses in Systems Supporting
the US-VISIT Program
DATE: 07/13/2007
SUBJECT: Biometrics
Computer networks
Computer security
Data encryption
Homeland security
Immigration
Information security
Information systems
Internal controls
DHS Visitor and Immigrant Status
Indicator Technology Program
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GAO-07-870
* [1]Results in Brief
* [2]Background
* [3]Overview of the US-VISIT Program
* [4]Goals and Purpose
* [5]Information Systems Supporting the US-VISIT Program
* [6]US-VISIT Port of Entry Processing
* [7]Systems Supporting US-VISIT Biographic Checks
* [8]Systems Supporting US-VISIT Biometric Checks
* [9]Roles and Responsibilities for Systems Supporting
US-VISIT
* [10]Information and Information Systems Supporting US-VISIT
Need
* [11]Objective, Scope, and Methodology
* [12]Significant Weaknesses Place US-VISIT Data at Risk
* [13]Access Controls are Inadequate
* [14]Identification and Authentication
* [15]Authorization
* [16]Boundary Protection
* [17]Physical Security
* [18]Cryptography
* [19]Audit and Monitoring
* [20]Weaknesses in Other Information System Controls Increase Ris
* [21]Segregation of Duties
* [22]Configuration Assurance
* [23]Aggregate Effect of Weaknesses
* [24]Information Security Program Is Not Fully Implemented
* [25]Risk Assessment
* [26]Security Plans
* [27]Security Testing
* [28]Remedial Actions
* [29]Incident Detection and Handling
* [30]Implementation of Policies Involving Personally
Identifiable
* [31]Conclusions
* [32]Recommendations for Executive Action
* [33]Agency Comments
* [34]GAO Contacts
* [35]Staff Acknowledgments
* [36]GAO's Mission
* [37]Obtaining Copies of GAO Reports and Testimony
* [38]Order by Mail or Phone
* [39]To Report Fraud, Waste, and Abuse in Federal Programs
* [40]Congressional Relations
* [41]Public Affairs
Report to Congressional Requesters
United States Government Accountability Office
GAO
July 2007
INFORMATION SECURITY
Homeland Security Needs to Immediately Address Significant Weaknesses in
Systems Supporting the US-VISIT Program
GAO-07-870
Contents
Letter 1
Results in Brief 2
Background 3
Objective, Scope, and Methodology 17
Significant Weaknesses Place US-VISIT Data at Risk 18
Conclusions 33
Recommendations for Executive Action 34
Agency Comments 35
Appendix I Comments from the Department of Homeland Security 37
Appendix II GAO Contacts and Staff Acknowledgments 40
Figures
Figure 1: Simplified Diagram of Key Systems supporting US-VISIT 14
Figure 2: Types of information used by the US-VISIT program 16
Abbreviations
ADIS Arrival and Departure Information System
CCD Consular Consolidated Database
CBP United States Customs and Border Protection
CSIRC Computer Security Incident Response Center
DHS Department of Homeland Security
FISMA Federal Information Security Management Act
ICE United States Immigration and Customs Enforcement
IDENT Automated Biometric Identification System
INS Immigration and Naturalization Service
ISA Interconnection Security Agreement
IT Information Technology
LAN Local-area Network
NCIC National Crime Information Center
NIST National Institute of Standards and Technology
OMB Office of Management and Budget
PIA Privacy Impact Assessment
POA&M Plan of Action and Milestones
SORN System of Records Notice
TECS Treasury Enforcement Communications System
TECS/IBIS Treasury Enforcement Communications System/ Interagency Border
Inspection System
USCIS United States Citizenship and Immigration Services
US-VISIT United States Visitor and Immigrant Status Indicator Technology
WAN Wide-area Network
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separately.
United States Government Accountability Office
Washington, DC 20548
July 13, 2007
The Honorable Joseph I. Lieberman
Chairman
Committee on Homeland Security and Governmental Affairs
United States Senate
The Honorable Bennie G. Thompson
Chairman
Committee on Homeland Security
House of Representatives
In the years since the 2001 terrorist attacks, the need to secure U.S.
borders has taken on added importance and has received increasing
attention from Congress and the public. In an effort to avoid repetition
of such attacks, and improve overall national security, Congress and the
Administration have sought better ways to record and track the entry and
departure of foreign visitors who pass through U.S. ports of entry^1 by
air, land, or sea; to verify their identities; and to authenticate their
travel documentation. Pursuant to several statutory mandates, the
Department of Homeland Security (DHS), in consultation with the Department
of State, established the United States Visitor and Immigrant Status
Indicator Technology (US-VISIT) program.
As the federal government strives to integrate information on the entry
and exit from the United States of foreign nationals, it is critical that
the computer systems that support US-VISIT are properly protected through
strong information security controls since a security breach could have a
direct impact on our homeland and the security of U.S. citizens. For
example, if controls for systems supporting US-VISIT were inadequately
implemented there is a risk that unauthorized individuals could (1) delete
or alter visitor records used or processed by US-VISIT and allow a drug
smuggler, terrorist, or convicted felon to illegally enter the United
States or (2) mount denial of service attacks and cripple computer
processing at U.S. air, land, and sea ports of entry as well as the
networks and infrastructure that support these ports of entry.
^1A port of entry is generally a physical location, such as a pedestrian
walkway and/or a vehicle plaza with booths, and associated inspection and
administration buildings, at a land border crossing point, or a restricted
area inside an airport or seaport, where entry into the country by persons
and cargo arriving by air, land, or sea is controlled by U.S. Customs and
Border Protection (CBP).
As agreed, our objective was to determine whether the Department of
Homeland Security has implemented appropriate information security
controls to protect the confidentiality, integrity, and availability of
the information and systems used to support the US-VISIT program. To
accomplish this objective, we examined the controls over the systems
operated by the United States Customs and Border Protection (CBP) that
support the US-VISIT program. We performed our review at CBP facilities in
the Washington, D.C. metropolitan area and selected ports of entry on the
East and West Coast of the continental United States from February 2006
through April 2007, in accordance with generally accepted government
auditing standards.
In a separate report designated "Limited Official Use Only," we are
providing a more detailed discussion of the information security
weaknesses affecting US-VISIT applications and additional technical
recommendations.
Results in Brief
Significant weaknesses in computer security controls threaten the
confidentiality, integrity, and availability of critical CBP information
and information systems used to support the US-VISIT program. CBP did not
implement controls to effectively prevent, limit, and detect access to
computer networks, systems, and information. For example, it did not (1)
adequately identify and authenticate users in systems supporting US-VISIT;
(2) sufficiently limit access to US-VISIT information and information
systems; (3) ensure that controls adequately protected external and
internal boundaries; (4) effectively implement physical security at
several locations; (5) consistently encrypt sensitive data traversing the
communication network; and (6) provide adequate logging or user
accountability for the mainframe, workstations, or servers. In addition,
CBP did not always ensure that responsibilities for systems development
and system production were sufficiently segregated and did not
consistently maintain secure configurations on the application servers and
workstations at a key data center and ports of entry. As a result,
increased risk exists that unauthorized individuals could read, copy,
delete, add, and modify sensitive information--including personally
identifiable information--and disrupt service on CBP systems supporting
the US-VISIT program.
A key reason for these weaknesses was that, although CBP made important
progress in implementing elements of the department's information security
program, it did not effectively or fully implement key program activities.
For example, CBP did not fully characterize the risks facing critical
systems, update interconnection security agreements in security plans,
sufficiently test and evaluate security controls, incorporate required
elements in remedial action plans, adequately implement incident detection
and handling procedures, and consistently address privacy issues.
We are making six recommendations to the Secretary of Homeland Security to
effectively and fully implement key information security program
activities for systems supporting US-VISIT.
In written comments on a draft of this report (which are reprinted in app.
I), DHS' Director of the Departmental GAO/OIG Liaison Office stated that
CBP concurred with our recommendations and that CBP has already taken a
number of significant steps toward mitigating many of the reported
weaknesses. The director also stated that the department has directed CBP
to complete remediation activities to address each of the six
recommendations.
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 maintaining the public's trust is essential. The dramatic expansion
in computer interconnectivity and the rapid increase in the use of the
Internet have changed the way our government, the nation, and much of the
world communicate and conduct business. However, without proper
safeguards, systems are unprotected from individuals and groups with
malicious intent to intrude and use the access to obtain sensitive
information, commit fraud, disrupt operations, or launch attacks against
other computer systems and networks. This concern is 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 technology, and
the dire warnings of new and more destructive attacks to come.
Recognizing the importance of securing federal agencies' information and
systems, Congress enacted the Federal Information Security Management Act
of 2002 (FISMA) to strengthen the security of information and systems
within federal agencies.^2 FISMA requires each agency to use a risk-based
approach to develop, document, and implement a departmentwide information
security program for the information and systems that support the
operations and assets of the agency.
Overview of the US-VISIT Program
The Congress has long recognized the need for a border security system
that collects information about foreign nationals entering and exiting the
United States and identifies those who have overstayed their visits.
Legislative efforts to create an entry exit control system to record and
match arrival and departure records for foreign nationals traveling to the
United States began as early as 1996 with the Illegal Immigration Reform
and Immigrant Responsibility Act (IIRIRA).^3 Among other things, Section
110 of the of IIRIRA directed the former Immigration and Naturalization
Service (INS) to develop an automated entry exit control system to collect
records of departure from every alien leaving the United States and match
it with the alien's record of arrival. In 2000, the Immigration and
Naturalization Service Data Management Improvement Act^4 amended section
110 of IIRIRA by replacing it in its entirety. This act, among other
things, requires that the entry exit system integrate alien arrival and
departure information contained in Department of Justice (including INS)
and State Department databases.
Since September 11, 2001, additional laws address, among other things, the
use of biometric technology in an alien entry exit control system. For
example, the USA PATRIOT Act^5 mandates that this system be capable of
interfacing with other law enforcement agencies, and that it uses
biometric technology and tamper-resistant documents. In addition, the
Aviation and Transportation Security Act^6 requires air carriers to
electronically transmit manifest information for all international flight
passengers and crew members to the Commissioner of Customs before landing
at a U.S. airport. Furthermore, the Enhanced Border Security and Visa
Entry Reform Act^7 further requires the use of biometrics in travel
documents and expands the passenger arrival manifest requirements in the
Aviation and Transportation Security Act to sea carriers and to air and
sea departures.
^2FISMA was enacted as title III, E-Government Act of 2002, Pub. L. No.
107-347 (Dec. 17, 2002).
^3Pub. L. No. 104-208 (Sept. 30, 1996), Div. C, sec. 110.
^4Pub. L. No. 106-215 (June 15, 2000), sec. 2(a).
^5Pub. L. No. 107-56 (Oct. 26, 2001), sec. 414. The official title of this
act is the United and Strengthening America by Providing Appropriate Tools
Required to Intercept and Obstruct Terrorism (USA PATRIOT Act) Act of
2001.
^6Pub. L. No. 107-71 (Nov. 19, 2001), sec. 115.
With the passage of the Homeland Security Act of 2002,^8 22 federal
agencies and organizations merged into the Department of Homeland Security
(DHS). Shortly after DHS assumed operational control, the Secretary of the
Department of Homeland Security renamed the entry exit system US-VISIT.
Most recently, the Intelligence Reform and Terrorism Prevention Act of
2004^9 calls for the Secretary of the Department of Homeland Security to
accelerate the full implementation of an automated biometric entry and
exit data system. Among other things, the act requires the biometric entry
exit screening system to provide real-time updates on all information
about entry exit history to relevant agencies.
Today, the US-VISIT program is a multi-agency initiative. From fiscal year
2002 through fiscal year 2007, total funding for the US-VISIT program has
been about $1.7 billion dollars.
Since fiscal year 2002, Congress has directed GAO to review annual DHS
plans, also called expenditure plans, describing how the agency plans to
satisfy legislative conditions specified in the appropriations, including
acting and complying with federal acquisition rules, requirements,
guidelines, and systems acquisition management practices. These reviews
have produced five reports, the latest being a review of the fiscal year
2006 US-VISIT expenditure plan.^10 These reports and other recent reports
on US-VISIT contract and financial management^11 and US-VISIT operations
at land ports of entry have identified fundamental challenges that DHS
continues to face in meeting program expectations (i.e., delivering
program capabilities and benefits on time and within cost).^12 We have
made many recommendations over the last 4 years to DHS to define and
justify US-VISIT's future direction, strengthen program management, and
ensure the delivery of promised system capabilities on time and within
budget.
^7Pub. L. No. 107-173 (May 14, 2002), sec 302, 303, 401 & 402.
^8Pub. L. No. 107-296 (Nov. 25, 2002).
^9Pub. L. No. 108-458 (Dec. 17, 2004), sec. 7208.
Goals and Purpose
The goals of the US-VISIT program are to (a) enhance the security of U.S.
citizens and visitors, (b) facilitate legitimate travel and trade, (c)
ensure the integrity of the U.S. immigration system, and (d) protect the
privacy of our visitors. Key US-VISIT functions include:
o collecting, maintaining, and sharing information on certain
foreign nationals who enter and exit the United States;
o identifying foreign nationals who (1) have overstayed or
violated the terms of their admission; (2) may be eligible to
receive, extend, or adjust their immigration status; or (3) should
be apprehended or detained by officials;
o detecting fraudulent travel documents, verifying traveler
identity, and determining traveler admissibility through the use
of biometrics; and
o facilitating information sharing and coordination within the
immigration and border management community.
^10GAO, Information Technology: Homeland Security Needs to Improve Entry
Exit System Expenditure Planning, [42]GAO-03-563 (Washington, D.C.: June
9, 2003); GAO, Homeland Security: Risks Facing Key Border and
Transportation Security Program Need to Be Addressed, [43]GAO-03-1083
(Washington, D.C.: Sept. 19, 2003); GAO, Homeland Security: First Phase of
Visitor and Immigration Status Program Operating, but Improvements Needed,
[44]GAO-04-586 (Washington, D.C.: May 11, 2004); GAO, Homeland Security:
Some Progress Made, but Many Challenges Remain on U.S. Visitor and
Immigrant Status Indicator Technology Program, [45]GAO-05-202 (Washington,
D.C.: Feb. 23, 2005); and GAO, Homeland Security: Planned Expenditures for
U.S. Visitor and Immigrant Status Program Need to Be Adequately Defined
and Justified, [46]GAO-07-278 (Washington, D.C.: Feb. 14, 2007).
^11GAO, Homeland Security: Contract Management and Oversight for Visitor
and Immigrant Status Program Need to Be Strengthened, [47]GAO-06-404
(Washington, D.C.: June 9, 2006).
^12GAO, Homeland Security: US-VISIT Has Not Fully Met Expectations and
Longstanding Program Management Challenges Need to Be Addressed,
[48]GAO-07-499T (Washington, D.C.: February 16, 2007).
Information Systems Supporting the US-VISIT Program
The US-VISIT program is implemented via a "system-of-systems"^13
in that the program is composed of different systems that are used
to capture and store traveler information. Traveler information
captured by US-VISIT includes such information as air, land, and
sea port of entry admission data, commercial passenger and crew
data, visa application data, and travel document (passport and
visa) data. The type of data captured includes the person's
complete name, date of birth, nationality, travel document issuing
country, travel document number and type, applicant photo, and
finger scans.^14
The scope of the program includes the pre-entry,^15 entry,^16
status management,^17 and exit^18 of foreign national travelers
who enter and leave the United States at 285 air, land, and sea
ports of entry, and the provision of new analytical capabilities
across the overall process. The entry aspect of the program, and
the systems that support entry, are described below.
US-VISIT Port of Entry Processing
When the applicant for admission arrives at a primary inspection
booth, the CBP officer, using a document reader, scans the
traveler's machine-readable travel documents or manually enters
the information into a biographic system if the traveler is not in
possession of machine readable documents. A biographic check is
then made of the traveler to identify individuals who (1) are not
known to pose a threat or is not suspected of posing a threat to
the security of the United States; (2) have not violated the terms
of their admission to the United States; or (3) are not wanted for
commission of a criminal act in the United States or elsewhere. In
addition, a photograph and summary biographical information of the
individual is also displayed in cases where the individual has
been issued a travel document by the Department of State or by
DHS.
^13A "system of systems" is a group of interdependent systems that are
related or connected to provide a given capability. The loss of any part
of the system will degrade the performance or capabilities of the whole.
^14A finger scan is an inkless capture of finger ridge pattern images.
^15Pre-entry refers to processes designed to evaluate a traveler's
eligibility for required travel documents, enroll travelers in automated
inspection programs, and pre-screen travelers entering the U.S.
^16Entry refers to the process of determining a traveler's admissibility
to the U.S. at air, land, or sea ports of entry.
^17Status management is the process of managing and monitoring the changes
and extensions of the visits of lawfully admitted non-immigrant foreign
nationals to ensure that they adhere to the terms of their admission and
to notify appropriate government entities when they do not.
^18Exit refers to the process of collecting information regarding persons
departing the U.S.
Following the biographic check of the traveler by the CBP officer
at the primary inspection booth, the officer then switches to a
second biometric system to capture information pertaining to each
traveler. The officer scans the individual's fingerprints (left
and right index fingers) and takes a photograph.
While the system is checking the finger scan, the officer
questions the foreign national about the purpose of his or her
travel and length of stay. If the officer determines the traveler
is admissible, the officer enters the class of admission^19 and
duration of stay information into the system and also annotates
the class of admission and "admit until" date on the I-94 form.^20
The officer in the primary inspection booth then receives either a
red or green light from the system indicating the results of the
query. For example, if the query from the biographic system
returns derogatory information or if the document issuance
information does not match the traveler, the officer gets a red
light from the system and then refers the traveler to secondary
inspection for further questioning or actions. If the individual
is then determined to be inadmissible in secondary inspection, the
person is processed for removal or other actions.^21 This
information is then entered into the system by officers at the
secondary inspection area and the appropriate actions are taken.
^19A class of admission is a specific category to which an alien lawfully
enters the United States, following inspection and authorization by an
immigration officer.
^20The I-94 form is used to track the arrival and departure of
nonimmigrants. It is divided into two parts. The first part is an arrival
portion, which includes, for example, the nonimmigrant's name, date of
birth, and passport number. The second part is a departure portion, which
includes the name, date of birth, and country of citizenship.
^21Travelers are processed by US-VISIT at primary and secondary inspection
at air and sea ports of entry. At land ports of entry, visitors are only
processed by US-VISIT at secondary inspection.
A green light indicates that the traveler's biometrics did not
match any records in the US-VISIT biometric watch list and, in
cases of repeat travelers; there was no mismatch against the
biometric data captured from the traveler's prior arrival(s).
Systems Supporting US-VISIT Biographic Checks
The biographic system referred to above for the biographic check
is performed by a system called the Treasury Enforcement
Communications System/ Interagency Border Inspection Service
(TECS/IBIS).^22 The IBIS "service" serves as a centralized, shared
database of textual enforcement and lookout information,
containing well over 10 million subject records. It supports
approximately two dozen federal and other agencies^23 and it
resides on a CBP mainframe computer. IBIS keeps track of
information on suspect individuals, businesses, vehicles,
aircraft, and vessels. The types of data contained on the IBIS
"watch list" include information from a variety of federal, state
and local sources, which contributes to effective national
security and law enforcement. Personal information about these
individuals includes, but is not limited to, name, alias, date of
birth, address, physical description, details and circumstances of
a search, arrest, or seizure, case information such as merchandise
and values, and methods of theft.
Other Treasury Enforcement Communication System (TECS) systems
besides IBIS that support US-VISIT are the
o Advance Passenger Information System (APIS), a system that
returns current passenger and crew manifest records on individuals
arriving into and departing from the U.S. APIS includes arrival
and departure manifest information provided by air and sea
carriers such as name, date of birth, travel document issuing
country, gender, U.S. destination address, entry date, and
departure date; and
o I-94, a system which has information derived from I-94 arrival
and departure forms.
^22Hereafter referred to as "IBIS."
^23Some of these agencies are the Federal Bureau of Investigation,
Interpol, Drug Enforcement Administration, Bureau of Alcohol, Tobacco, and
Firearms, the Internal Revenue Service, the Coast Guard, the Federal
Aviation Administration, the Secret Service, and the Animal Plant Health
Inspection Service. Also, information from IBIS is shared with the
Department of State for use by Consular Officers at U.S. Embassies and
Consulates.
CBP officers also have access to other TECS watch lists that
according to US-VISIT officials are not used in conjunction with
US-VISIT but are used in the border management process. For
example, two systems which CBP officers have access through IBIS
are (1) the National Crime Information Center (NCIC) database
which was established by the Department of Justice as a service to
all criminal justice agencies, as well as federal, state, and
local users; and (2) the National Law Enforcement
Telecommunication System (NLETS), which allows queries on state
criminal history, vehicle registration, driver's license
information, and administrative messages.
In addition, the Automated Targeting System-Passenger is a module
used at all U.S. airports and seaports receiving international
flights and voyages to evaluate passengers and crew members prior
to arrival or departure. US-VISIT officials told us that, although
the system is not used in support of US-VISIT, it is used in the
CBP officer's decision-making process about whether a passenger or
crewmember should receive additional screening prior to entry into
or departure from the country.
Systems Supporting US-VISIT Biometric Checks
The biometric^24 system behind the finger scan processing
described above is complex as well. For example, after the CBP
officer at the port of entry scans the fingerprints and takes a
digital photograph of the visitor, the finger scans and photograph
are sent to a system called the Automated Biometric Identification
System (IDENT) which is managed by the US-VISIT program office.
IDENT contains information on (1) known and suspected terrorists;
(2) selected wanted persons (foreign-born, unknown place of birth,
previously arrested by DHS); (3) deported felons and sexual
registrants; (4) certain previous criminal histories; and (5)
previous IDENT border crossing enrollments. Also included in IDENT
is information on persons who have attempted illegal entry into
the United States, persons who have applied for immigration and
naturalization benefits, and persons who have applied for
positions of public trust.
IDENT checks visitors at U.S. borders against a US-VISIT biometric
watch list of individuals for whom biometrics have been collected.
These individuals include:
^24In the context of US-VISIT, biometrics consists of digital inkless
finger scan images and a digital photograph of the visitor.
o known or suspected terrorists,
o wanted individuals,
o deported felons, and
o individuals related to gang activity.
Information on these individuals comes from a variety of sources,
including
o the Federal Bureau of Investigation,
o Interpol,
o the California Department of Justice,
o the Los Angeles County Sheriff's Office,
o the Department of Defense, and
o Department of State visa application refusals.
Each of the above organizations has its own computer systems
sending data to IDENT. For example, in the case of the Department
of State, IDENT receives enrollment data and visa refusal data
from Consular officers abroad who collect finger scans as part of
the visa issuance process. When the visa applicant's finger scans
are captured, they are electronically sent, along with a digital
photo of the applicant and biographic data, to the Department of
State's Consular Consolidated Database (CCD)^25 and from CCD the
finger scans and photo are sent to IDENT.^26 Information about the
photo is also sent from the CCD to a TECS database called US-VISA
Datashare. Information from the FBI comes to IDENT from the FBI's
Integrated Automated Fingerprint Identification System.
^25U.S. consular offices supporting US-VISIT collect biographic
information, to include a photo as well as biometrics from the foreign
national seeking to enter the United States and send it to the Consular
Consolidated Database.
^26The Department of State CCD connects to both TECS and IDENT. CCD
collects and sends finger scans to IDENT but does not store them. IDENT is
the sole repository for finger scans collected on behalf of the US-VISIT
program.
The IDENT system performs three basic biometric operations:
identification, verification, and enrollment. Identification
consists of searching databases, such as terrorist watch lists, to
ensure that known or suspected terrorists are not admitted into
the U.S. In verification, the claimed identity of a foreign
visitor is confirmed by comparing the biometrics of an individual
with stored biometrics associated with a travel document, such as
a passport or visa. Enrollment "registers" individuals into the
IDENT database. IDENT also stores finger scans collected during
the inspection if they are of better quality than those already
stored within the system.
IDENT in turn transmits the finger scan identification numbers
associated with biometrics captured at arrival in the United
States to the Arrival Departure Information System (ADIS). ADIS,
which is "owned" by the US-VISIT program office,^27 is a database
that stores traveler arrival, status management, and departure
data. Arrival and departure data is received from (1) air and sea
carrier manifests; (2) inspector data entries at ports of entry;
(3) I-94 forms; and (4) biometric identifiers collected at arrival
and certain departure locations. It matches entry, immigration
status updates, and departure data to provide up-to date
immigration status, including whether the individual has
overstayed his/her authorized period of stay.
ADIS also receives information from a variety of other sources.
For example, information on student change of status is received
from the Student and Exchange Visitor Information System (SEVIS).
Schools and sponsors transmit information to SEVIS via the
Internet throughout a foreign student's or exchange visitor's stay
in the U.S.^28 SEVIS in turn provides this information to ADIS.
Another system called the Computer Linked Application Information
Management System (CLAIMS 3) also sends information to ADIS.
CLAIMS 3 is a system that contains information, including
adjudication results on foreign nationals who request immigration
benefits such as change of status, extension of stay, or
adjustment to permanent resident status.
^27However, the ADIS contract is managed by CBP.
^28SEVIS applies to F, J, and M visa nonimmigrants and their dependents
only. F visa nonimmigrants are foreign students pursuing a full course of
study in a college, university, seminary, conservatory, academic high
school, private elementary school, other academic institution, or language
training program in the United States that has been approved to enroll
foreign students. J nonimmigrants are foreign nationals who have been
selected by a sponsor designated by the Department of State to participate
in an exchange visitor program in the United States. M nonimmigrants are
foreign students who are pursuing a full course of study in a vocational
school or other recognized nonacademic institution in the United States
that has been certified to enroll foreign students.
ADIS consolidates the biometric and biographic information and
transmits information to TECS linking the travelers' biographic
information to their biometrics. ADIS transmits this information
to the TECS Biometric Information File, which includes the
traveler's name, date of birth, travel document information and
the associated biometric identification number.
As in the case of the biographic watchlists, the inspector has
access to additional watchlists that are not part of the
functionality of US-VISIT but are important in border management.
For example, if a "match" is received from IDENT during primary
inspection, the encounter data is stored as part of the US-VISIT
process, and the traveler would be sent to secondary inspection
for further action. During secondary inspection processing, the
officer can access US-VISIT systems such as IDENT's Secondary
Inspection Tool and ADIS to receive additional information, but
the officer will also separately log into other CBP systems or
interconnections such as NCIC, to retrieve the full case
management information as part of the CBP border management and
enforcement process.
Figure 1 is a simplified diagram of key computer systems and
networks that support the US-VISIT program.
Figure 1: Simplified Diagram of Key Systems supporting US-VISIT
As shown in the diagram, air, land, and sea ports of entry are connected
to Customs and Border Protection local-area networks^29 which are
connected to a wide-area network.^30 The wide-area network is in turn
connected to a data center network which houses a mainframe computer
supporting TECS. The Customs and Border Protection data center network is
also connected to other networks, such as the Department's wide-area
network and the Immigration and Customs Enforcement network, where the
IDENT and ADIS are located. Other government agencies such as the
Department of State receive biometric and biographic data via the Customs
and Border Protection data center network. Nongovernmental networks such
as private sector trade business networks transmit passenger and crew
manifest data to the data center network.
^29A local area network is the cabling, hardware, and software used to
connect workstations, computers, and file servers located in a confined
geographical area (typically within one building or campus).
^30A wide area network is a network that provides data communications to a
large number of independent users and spans a large geographical area.
Roles and Responsibilities for Systems Supporting US-VISIT
The US-VISIT Program Office is the information system owner^31 for several
of the systems that comprise US-VISIT functionality, such as the Automated
Biometric Identification System and the Arrival and Departure Information
System. However, the US-VISIT Program Office does not own all of the
systems that support the program. For example, the
o U.S. Customs and Border Protection is the system owner for
TECS,^32 the data center network, the wide-area network, and air,
land, and sea port of entry local-area local-area networks;
o U.S. Immigration and Customs Enforcement is the system owner for
the Student and Exchange Visitor Information System as well as the
network that supports the Automated Biometric Identification
System the Arrival and Departure Information System;
o U.S. Citizenship and Immigration Services is the system owner
for the Computer Linked Application Information Management System;
o U.S. Coast Guard is the system owner for e-mail services; and
o The Department of State owns the Consular Consolidated Database
system.
^31The information system owner has overall responsibility for the
procurement, development, integration, modification, operation, and
maintenance of the information system.
^32Some TECS components do not have a single system owner. For example,
CBP officials stated that there is no one system owner for TECS/IBIS;
rather it is a shared effort among all agencies that input data into it
and use it.
Information and Information Systems Supporting US-VISIT Need Protection
The US-VISIT program relies extensively on computerized networks
and systems to collect, access, or process a significant amount of
personal and sensitive information on foreign visitors,
immigrants, and legal permanent residents. Accordingly, effective
information security controls are essential to ensuring that this
information, depicted in figure 2, is adequately protected from
inadvertent or deliberate misuse, fraudulent use, improper
disclosure or manipulation, and destruction. The compromise of
this information could subject these citizens and visitors to
financial crimes such as identity theft and could impede the
Department of Homeland Security from achieving the goals of the
US-VISIT program.
Figure 2: Types of information used by the US-VISIT program
In addition, the US-VISIT program office has reported that threats
to US-VISIT systems and information exist, not only because they
are government assets, but also because they are a front line
defense in the government's anti-terrorist identification effort.
According to the program office, threats can fall into the broad
categories of insiders, hackers, domestic/foreign terrorists, and
other criminal elements. Because of their knowledge and access to
systems, insiders are in a position to modify an individual
computer system for personal gain, disrupt services, or embarrass
the agency. Hackers, on the other hand, are a significant concern
when connecting to the Internet. The specific attraction to
US-VISIT might be to embarrass US-VISIT or gain notoriety by
having defeated the security of an organization responsible for
the Nation's border security. The program office also maintains
that domestic or foreign terrorists are a threat since it is
conceivable that these radical subversive groups could target
US-VISIT to cause embarrassment to the program. Finally, other
criminal elements such as international terrorists, organized
crime, and foreign intelligence organizations could target
US-VISIT systems to obtain US-VISIT data on various border
programs.
Objective, Scope, and Methodology
The objective of our review was to determine whether DHS has
implemented appropriate information security controls to protect
the confidentiality, integrity, and availability of information
and information systems used to support the US-VISIT program. To
accomplish this, we used elements of our Federal Information
System Controls Audit Manual to evaluate information system
controls within the CBP control environment and concentrated our
efforts on the evaluation of logical access controls over major
systems, applications, and networks used by CBP in support of the
US-VISIT program. Selected systems included the US-VISIT aspects
of TECS, the data center mainframe that supports TECS, US-VISIT
interface servers, US-VISIT client applications, and the
supporting network and physical infrastructure such as servers,
routers, firewalls, and workstations for CBP components supporting
US-VISIT.
We reviewed results from other audits, assessments, and tests,
conducted interviews, and obtained and reviewed technical
documentation. In coordination with CBP officials, we identified
control points and obtained detailed configuration data from
selected devices. We then analyzed the output from each selected
device and reviewed the results in context to the network and for
impact on the mission.
In addition, we evaluated aspects of CBP's information security
program. This program includes assessing risk; developing and
implementing policies, procedures, and security plans; testing and
evaluating the effectiveness of controls; planning, implementing,
evaluating, and documenting remedial actions to address security
deficiencies; detecting, reporting, and responding to security
incidents; and ensuring privacy for personally identifiable
information. As part of this effort, we identified and examined
pertinent CBP security policies, procedures, guidance, security
plans, and relevant reports and reviewed corrective actions taken
by CBP to address vulnerabilities identified in previous reviews
and tests.
We discussed whether system controls were in place, adequately
designed, and operating effectively with key security
representatives, systems administrators, and management officials.
Our work was performed at DHS offices, a data center, and selected
air, land, sea ports of entry on the East and West coast of the
continental United States in accordance with generally accepted
government auditing standards.
Significant Weaknesses Place US-VISIT Data at Risk
Although CBP has implemented information security controls that
are designed to safeguard US-VISIT data, its systems supporting
US-VISIT have significant weaknesses in access controls and other
controls designed to protect the confidentiality, integrity, and
availability of its sensitive and personal information. CBP has
implemented several important controls such as encrypting data
transmitted between client and interface servers, deploying
intrusion detection software, and performing daily backup
procedures that synchronize the storage area network at a data
center with its remote backup site. In addition, it controlled
physical access systems for land and sea ports of entry and
effectively secured some of its sensitive areas and computer
equipment. However, CBP did not consistently implement effective
access controls and other controls such as segregation of duties
and configuration assurance for systems supporting US-VISIT. A key
reason for these weaknesses was that CBP did not always
effectively implement key program activities of the department's
information security program for systems supporting the US-VISIT
program. As a result, increased risk exists that unauthorized
individuals could compromise systems that support US-VISIT.
Access Controls are 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 access controls that are intended to
prevent, limit, and detect unauthorized access to computing
resources, programs, and information. These controls include
identification and authentication, authorization, boundary
protection, physical security, cryptography, and audit and
monitoring. Inadequate access controls diminish the reliability of
computerized information and increase the risk of unauthorized
disclosure, modification, and destruction of sensitive information
and the disruption of service.
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
must also 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. Users
are also responsible for providing protection against loss or
disclosure of passwords in their possession. DHS policy requires
the implementation of automated identification and authentication
mechanisms that enable the unique identification and
authentication of individual users or processes acting on behalf
of information system users.
DHS did not ensure that CBP adequately identified and
authenticated users in systems supporting US-VISIT. For example,
users shared passwords for accessing remote consoles, thereby
diminishing CBP's ability to attribute system activity to specific
individuals. Moreover, individuals with physical access to
workstations could change settings without authentication. In
addition, one application server owned by US-VISIT allowed logins
using vendor default credentials from CBP port of entry
workstations. As a result, increased risk exists that a malicious
individual could gain network access to CBP systems and sensitive
US-VISIT data.
Authorization
Authorization is the process of granting or denying access rights
and privileges to a protected resource, such as a network, system,
application, function, or file. A key component of authorization
and a basic principle for securing computer resources and data is
the concept of "least privilege." Least privilege means that users
are granted access to only those programs and files that they need
in order to perform their official duties. To restrict legitimate
users' access in this way, 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 have access to a
particular file or directory and the extent of that access. To
avoid unintentionally giving users unnecessary access to sensitive
files and directories, as well as special machine instructions
which programs used to communicate with the operating system, an
organization must give careful consideration to its assignment of
rights and permissions. DHS policy requires that each user or
process be assigned only those privileges needed to perform
authorized tasks.
CBP did not sufficiently limit access to US-VISIT information and
information systems. For example, over one thousand users with
command line access could put a program designed to bypass
security rules into a special system library. CBP users also
inappropriately had local administrator privileges on their
workstations that could be used to intentionally or
unintentionally load programs that may adversely affect security.
In addition, CBP did not effectively use access control lists to
control connectivity to sensitive applications and network devices
such as firewalls.
As a result, the unnecessary level of access granted to CBP
computer resources provided opportunities for individuals to
circumvent security controls and deliberately or inadvertently
read, modify, or delete critical or sensitive information relating
to the US-VISIT program.
Boundary Protection
Boundary protections demarcate logical or physical boundaries
between unknown users and protected information and systems. Best
practices dictate that organizations allocate publicly accessible
information system components to separate sub-networks with
separate physical network interfaces and that key components
within private networks are also adequately segregated as
sub-networks. Unnecessary connectivity to an organization's
network increases not only the number of access paths that must be
managed and the complexity of the task, but the risk of
unauthorized access in a shared environment. NIST guidance states
that organizations should control all remote access through a
managed access control point. DHS requires that any connections to
the Internet or to other external systems be through controlled
interfaces. For example, DHS requires that any direct connection
of DHS networks to the Internet or to extranets must occur through
firewalls that have been certified and accredited.
However, DHS did not ensure that controls adequately protected
external and internal boundaries. For example, internal network
traffic was not segregated. Moreover, workstations and many
servers did not have host based firewalls. Consequently, there is
a heightened risk that security checkpoints at the boundaries of
CBP's network may not inspect all traffic entering the network. As
a result, increased risk exists that individuals could gain
unauthorized access to sensitive information and systems.
Physical Security
Physical security controls are important for protecting computer
facilities and resources from espionage, sabotage, damage, and
theft. These controls restrict physical access to computer
resources, usually by limiting access to the buildings and rooms
in which the resources are housed, and by periodically reviewing
the access granted in order to ensure that it continues to be
appropriate.
DHS policy requires (1) that physical access to rooms, work areas
and spaces, and facilities containing departmental systems,
networks, and data be limited only to authorized personnel and (2)
the implementation of environmental controls that safeguard agency
assets against loss, theft, destruction, accidental damage,
hazardous conditions, fire, malicious actions, and natural
disasters. CBP policy states that information assets are required
to have consistent and documented protection, similar to a
"defense-in-depth" concept, which means there are multiple layers
of security protecting an asset.
However, CBP did not effectively implement physical security at
several locations. For example, CBP did not control access to its
restricted information technology spaces since its physical access
systems were controlled by local authorities. In addition,
sensitive information technology areas at CBP were not adequately
secured and many rooms containing sensitive IT equipment had no
environmental controls. As a result, these weaknesses increase the
risk that unauthorized personnel could access sensitive CBP
computing resources supporting US-VISIT and inadvertently or
deliberately access, misuse, or destroy network resources.
Cryptography
Cryptography^33 underlies many of the mechanisms used to enforce
the confidentiality and integrity of critical and sensitive
information. One primary principle of cryptography is encryption.
Encryption can be used to provide basic confidentiality and
integrity for data by transforming plain text into cipher text
using a special value known as a key and a mathematical process
known as an algorithm. DHS requires the encryption of highly
sensitive system files.
^33Cryptography is the discipline that embodies principles, means, and
methods for providing information security, including confidentiality,
data integrity, non-repudiation, and authenticity.
DHS did not consistently apply encryption to protect sensitive
data traversing the communication network. For example, network
routers, switches, and network management servers used unencrypted
network protocols so that files traversing the network could be
read. In addition, passwords were transmitted over the network in
clear text and were stored using weak encryption. US-VISIT
applications also used a single key to encrypt all communications
between the clients and servers so that sensitive US-VISIT data
could be compromised should the key be captured and decrypted. CBP
also did not appropriately distribute its private certificate
authority^34 and users relied on unknown certificates. In
addition, CBP applications did not assign unique certificates and
used the same certificate for both the client and the server. As a
result, these weaknesses could allow an attacker to have
unauthorized access to CBP network resources on the internal
network and view or modify the messages between the servers and
any client supporting US-VISIT.
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 of needed information in the desired format and locations so
they can use it 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 the audit
trails can provide. A key aspect of this is management of audit
logs.^35 Organizations should periodically review audit log
design, processes and procedures and implement changes as needed
to ensure that logs effectively detect security threats.
DHS policy requires the enforcement of auditing and accountability
by configuring information systems to produce, store, and retain
audit records of system, application, network, and user activity.
DHS also requires that audit records contain sufficient
information to establish what events occurred, when the events
occurred, the source of the events, the cause of the events, and
the event outcome. CBP also developed and implemented a monitoring
list that tracks access to key operating system libraries with
programs allowed to execute restricted functions.
^34A certificate authority is a provider that issues and manages security
credentials and public keys for message encryption and decryption. As part
of a public key infrastructure, a certificate authority checks with a
registration authority to verify information provided by the requester of
a digital certificate. If the registration authority verifies the
requester's information, the certificate authority can then issue a
certificate.
^35Log management is the process for generating, transmitting, storing,
analyzing, and disposing of log data.
CBP did not provide adequate logging or user accountability for
the mainframe, workstations, or servers. For example, monitoring
lists for key operating system libraries on the mainframe did not
capture needed data for all sensitive libraries in the desired
locations. In addition, the monitoring list for key operating
system libraries was out of date and irrelevant since it focused
on 680 items that were no longer on the system. CBP also did not
install central logging servers to ensure that key
security-relevant events could be easily reviewed and safeguarded.
As a result, CBP may allow unauthorized logical access to US-VISIT
systems to go undetected.
Weaknesses in Other Information System Controls Increase Risks
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, segregation of duties is achieved 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. DHS policy requires that segregation of duties be
observed in order to eliminate conflicts of interest in the
responsibilities and duties assigned to individuals.
CBP did not always ensure that responsibilities for systems
development and system operations or production were sufficiently
segregated. For example, development and test servers and a
development code repository were on the production network. In
addition, mainframe system programmers were allowed to access
application production data and developmental staff could access
mainframe operating system libraries. Moreover, developmental
staff had update access to the application production data. As a
result, potential risk exists for these individuals to perform
incompatible functions and increases the likelihood that they can
corrupt critical processes.
Configuration Assurance
Configuration assurance is the process of (1) verifying the
correctness of the security settings in the operating systems,
applications, or computing and network devices and (2) maintaining
operations in a secure fashion. Patch management is an important
element in mitigating the risks associated with software
vulnerabilities. When software vulnerabilities are discovered, the
software vendor may develop and distribute a patch or work-around
to mitigate the vulnerability. DHS patch management policy states
that components shall manage systems to reduce vulnerabilities by
installing patches. Both DHS and CBP policies state that security
patches need to be installed on servers and desktops in a timely
and expeditious manner. Outdated and unsupported software are more
vulnerable to attacks and exploitation. NSA guidance also states
that it is important to install periodic updates to the operating
system, since these updates contain fixes to vulnerabilities.
CBP has taken steps to ensure that patches for the Windows
operating systems were kept up-to-date. For example, CBP officials
informed us that (1) CBP has documented its patch deployment
process, manual patching procedures, and scan procedures for
Windows and that (2) the Security Operations Center uses an
automated tool to install patches on Windows devices within the
ports of entry, the CBP wide-area network, and the CBP
infrastructure.
However, CBP did not consistently maintain secure configurations
on the mainframe, applications servers, and workstations we
reviewed at the data center and ports of entry. For example,
production servers and workstations were missing critical
operating system and software application security patches. CBP
also used outdated versions of software and products that were no
longer supported by the vendor. Further, CBP could not implement
critical security features because it had not deployed the
appropriate software on some workstations.
As a result, increased risk exists that the integrity of the CBP
mainframe, network devices, and administrator workstations
supporting US-VISIT could be compromised and could lead to
denial-of-service attacks or to individuals gaining unauthorized
access to network resources.
Aggregate Effect of Weaknesses
The aggregate effect of inadequate access controls and weaknesses
in other system controls place information and information systems
supporting US-VISIT at increased risk of unauthorized disclosure,
use, modification, or destruction, possibly without detection.
These weaknesses increase the risk that unauthorized individuals
could read, copy, delete, add, and modify sensitive
information--including personally identifiable information--on
systems supporting the US-VISIT program. They make it possible for
intruders, as well as government and contractor employees, to
bypass or disable computer access controls and undertake a wide
variety of inappropriate or malicious acts. These acts could
include tampering with data; browsing sensitive information; using
computer resources for inappropriate purposes, such as launching
attacks on other organizations; and disrupting or disabling
computer-supported operations.
These risks are not confined to US-VISIT information. The CBP
mainframe and network resources that support US-VISIT also support
other programs and systems. As a result, the vulnerabilities
identified in this report could expose the information and
information systems of the other programs to the same increased
risks.
Information Security Program Is Not Fully Implemented
A key reason for these weaknesses is that, although CBP has made
important progress in implementing the department's information
security program, it has not effectively or fully implemented key
program activities for systems supporting the US-VISIT program.
CBP has taken several actions to implement elements of the
department's information security program. For example, it has
o developed, documented, and disseminated information security
policies, procedures, and plans. For example, CBP has (1) policies
on security; (2) procedures for incident handling and patch
management; and (3) configuration management plans;
o used Trusted Agent FISMA^36 as a tool to report component data
for enterprise management and oversight of the departmentwide
information security program;
o established a central security group that monitors systems such
as the ports of entry's regional local-area networks, and CBP's
wide-area network;
o established a security awareness training program. CBP reported
a 99 percent security awareness training completion rate for
employees and contractors for fiscal year 2006;
o implemented a central data repository for its business
continuity documents; and
o developed and tested continuity of operations and disaster
recovery plans for recovering the production environment at CBP's
data center which includes the TECS application.
^36Trusted Agent FISMA is a DHS enterprise compliance and oversight tool
used by CBP and other components to manage the collection and reporting of
key information security practices and controls.
DHS also requires its components to implement information security
program activities in accordance with FISMA requirements, OMB
policies, and applicable NIST guidance. Among other things, FISMA
requires agencies to develop, document, and implement
o periodic assessments of the risk and magnitude of harm that
could result from the unauthorized access, use, disclosure,
disruption, modification, or destruction of information or
information systems;
o plans for providing adequate information security for networks,
facilities, and systems or groups of information systems, as
appropriate;
o periodic testing and evaluation of the effectiveness of
information security policies, procedures, and practices,
performed with a frequency depending on risk, but no less than
annually, and that includes testing of management, operational,
and technical controls for every system identified in the agency's
required inventory of major information systems;
o a process for planning, implementing, evaluating, and
documenting remedial actions to address any deficiencies in
information security policies, procedures, and practices of the
agency;^37 and
o procedures for detecting, reporting, and responding to security
incidents.
^37OMB requires agencies to address remedial actions through plans of
action and milestones (POA&M) for all programs and systems where an
information technology security weakness has been found. The plan lists
the weaknesses and shows estimated resource needs, or other challenges to
resolving them, key milestones and completion dates, and the status of
corrective actions.
In addition, the E-Government Act of 2002 also requires agencies
to conduct privacy impact assessments (PIA) for information
systems to (1) ensure the system conforms to applicable legal,
regulatory, and policy requirements regarding privacy, (2)
determine the risks and effects of collecting, maintaining and
disseminating information in identifiable form in an electronic
information system, and (3) examine and evaluate protections and
alternative processes for handling information to mitigate
potential privacy risks.^38 Insofar as protecting personal privacy
is an essential element of information security, the privacy
impact assessment is an important means by which an agency can
identify related risks and needed information security controls.
However, CBP did not fully or effectively implement these program
activities. We identified risk assessments that did not fully
characterize the risks facing critical systems, security plans
that did not have updated interconnection security agreements,
tests and evaluations of security controls that were inadequate,
remedial action plans that lacked required elements, incident
detection and handling procedures that had not been adequately
implemented, and privacy issues that were not addressed in all
cases.
Risk Assessment
Identifying and assessing information security risks are essential
to determining what controls are required. By increasing awareness
of risks, these assessments can generate support for the policies
and controls that are adopted. NIST guidelines state that
identification of risk for IT systems require keen understanding
of the system's processing environment, including data and
information, system interfaces, system and data criticality, and
system and data sensitivity.
CBP completed risk assessments for the CBP mainframe and the local
area networks within the last 3 years and the risk assessments
identify key information such as threat sources, threat actions,
risk levels, and business impact as described in NIST guidelines.
However, the risk assessments CBP performed for systems supporting
the US-VISIT program did not always fully characterize risks to
the systems. For example, the risk assessment for TECS was
conducted without the benefit of (1) a completed privacy impact
assessment and (2) a complete inventory of all interconnections
between TECS and other systems. As a result, CBP has less
assurance that risks associated with these interconnections have
been properly identified and that privacy controls have been
implemented to mitigate risks.
^38OMB Guidance for Implementing the Privacy Provisions of the
E-Government Act of 2002, M-03-22, Sept. 26, 2003.
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. According to NIST guidance, security plans
should document all interconnected systems and describe the
interaction among systems with regard to the authorization for the
connection to other systems or the sharing of information. System
interconnections, if not appropriately protected, may compromise
connected systems and the data they store, process or transmit.
DHS policy states that security protections for interconnected
systems should be (1) documented in an interconnection security
agreement approved and signed by both parties and (2) updated
every three years or sooner whenever a significant change occurs
to any of the interconnected systems. According to DHS policy, an
interconnection security agreement is vital in protecting the
confidentiality, integrity, and availability of data processed
between interconnected systems.
However, 52 of the 57 interconnection security agreements listed
in the TECS security plan were not current since they had not been
updated within 3 years. Without updated interconnection security
agreements, CBP has limited assurance that appropriate security
controls have been identified and documented in system security
plans. Without current and complete documentation on the
interconnection of systems supporting US-VISIT, unintended access
may be granted to connecting parties and there is heightened risk
of compromise for connected systems and the data they store,
process, or transmit.
CBP officials have acknowledged that many interconnection security
agreements were not current and stated they are in the process of
updating the interconnection security agreements.
Security Testing
Another key element of an information security program is testing
and evaluating system controls to ensure that they are
appropriate, effective, and comply with policies. FISMA requires
that agencies test and evaluate the information security controls
of their major systems, and that the frequency of such tests be
based on risk, but occur no less than annually. NIST requires
agencies to ensure that the appropriate officials are assigned
roles and responsibilities for testing and evaluating controls
over systems. According to NIST, the security test results should
be documented and that the objectives of testing are to (1)
uncover design, implementation, and operational flaws that could
allow the violation of security policy; (2) determine the adequacy
of security mechanisms, assurances, and other properties to
enforce the security policy; and (3) assess the degree of
consistency between system documentation and its implementation.
In addition, DHS has provided guidance to its component agencies
on developing system test and evaluation plans, documenting the
results, and using an automated tool to capture test requirements
and test results. CBP test documentation did describe the
vulnerabilities that we found during our audit such as the absence
of one major application privacy impact assessment, the lack of
the application's interconnection security agreements, and patch
management problems at ports of entry's local-area networks.
However, CBP did not adequately test security controls. For
example, CBP tests of a major application and the mainframe did
not identify or discuss certain vulnerabilities that we identified
during our audit. Moreover, its testing did not reveal problems
with the mainframe that potentially allowed unauthorized users to
read, copy, change, delete, and modify US-VISIT and mainframe
data. In addition, although testing requirements were stated in
test documentation, the breadth and depth of the test, as well as
the results of the test, were not always documented. As a result,
without comprehensive tests and evaluations of security controls,
CBP has limited assurance that security mechanisms enforce the
security policy for systems supporting US-VISIT.
CBP officials have acknowledged that there are deficiencies in how
it documents, monitors, and reports test findings and stated that
they are taking steps to resolve these deficiencies.
Remedial Actions
The development and implementation of remedial action plans are
key components of an effective information security program. These
plans assist agencies in identifying, assessing, prioritizing, and
monitoring the progress in correcting security weaknesses that are
found in information systems. FISMA states that agencies must
develop a process for planning, implementing, evaluating, and
documenting remedial actions to address deficiencies in the
information security policies, procedures, and practices of the
agency.
According to OMB guidance, a plan of action and milestones is a
tool that identifies tasks that need to be accomplished and is to
assist agencies in identifying, assessing, prioritizing, and
monitoring the progress of corrective efforts for security
weaknesses found in programs and systems. The plan details
resources required to accomplish the elements of the plan, any
milestones in meeting the task, and scheduled completion dates for
those milestones. OMB also states that the resource estimates
should include the anticipated source of funding and whether a
reallocation of base resources or a request for new funding is
anticipated.
DHS policy requires, among other things, that (1) all
"significant" deficiencies be addressed by a remedial action plan;
(2) components use the Trusted Agent FISMA tool to identify,
track, and manage all IT system weaknesses and associated plans of
action and milestones to closure; (3) components identify an
action as completed only when a weakness has been fully resolved
and the corrective action has been tested and approved; and (4)
remedial action plans must identify the necessary resources to
correct identified weaknesses.
However, CBP did not always address significant deficiencies in a
remedial action plan as required by DHS policy. Several of these
exceptions resulted in vulnerabilities or exposed US-VISIT
information to increased risk of unauthorized disclosure and
modification. For example, CBP patch management weaknesses that
made workstations supporting US-VISIT vulnerable to attacks were
not addressed in a corresponding remedial action plan. In
addition, deficiencies found during security testing for the TECS
application supporting US-VISIT were also not always entered in
the Trusted Agent FISMA database. For example, 13 of the 19
exceptions found during security testing for one major
application, were not entered in the Trusted Agent FISMA database.
CBP also did not always accurately report the status of remedial
actions. Weaknesses that were only partially resolved were
sometimes reported as closed on remedial action plans. For
example, an Office of Inspector General recommendation that CBP
perform penetration testing was marked as "completed" in the
remedial action plan even though it was not addressed and
penetration testing was not performed for a key port of entry
application.
Furthermore, one application POA&M did not estimate the resources
to correct deficiencies. For example, this application's POA&M
stated that the requirement to authorize interconnections to all
systems was funded in a budget but the list of required resources
was described as "$0." As a result, without ensuring that remedial
action plans meet established requirements, CBP has limited
assurance that information system weaknesses affecting systems
supporting US-VISIT will be corrected in a timely manner.
Incident Detection and Handling
Even strong controls may not block all intrusions and misuse, but
organizations can reduce the risks associated with such events if
they take steps to promptly detect and respond to them before
significant damage is done. In addition, analyzing security
incidents allows organizations to gain a better understanding of
the threats to their information and the costs of their
security-related problems. Such analyses can pinpoint
vulnerabilities that need to be eliminated so that they will not
be exploited again. Incident reports can be used to provide
valuable input for risk assessments, help in prioritizing security
improvement efforts, and illustrate risks and related trends for
senior management. FISMA requires that agency information security
programs include procedures for detecting and reporting security
incidents. Furthermore, NIST guidance prescribes network and
host-based intrusion detection systems as a means of protecting
systems from the threats that come with increasing network
connectivity.
To ensure effective handling of incidents, DHS policy requires the
establishment and maintenance of an incident handling capability
that includes preparation, identification, containment,
eradication, and recovery. Preparation includes developing
policies and procedures, identifying supporting roles and
responsibilities, and establishing and implementing tools and
processes to ensure timely reporting of security incidents.
Identification includes determining the cause of a suspicious
event and notification to management. Containment includes
mitigating the risks of continuing to operate the affected system
by creating backups, keeping incident handlers informed, gathering
logs for review and changing passwords. Eradication involves
correcting the condition that caused the incident. Recovery
involves testing and validating the system before bringing it back
into production.
CBP has (1) established a Computer Security Incident Response
Center which is responsible for investigating, analyzing,
documenting, and resolving reported incidents; (2) implemented
policies and procedures pertaining to the preparation and
identification processes for handling incidents; and (3) described
what should be included in interconnection security agreements
such as the security policies that will be followed, how incidents
will be handled, and audit trail responsibilities for
interconnecting organizations.
However, CBP did not adequately establish and implement tools and
processes to ensure timely detection of security incidents. For
example, the CBP data center and the ports of entry have not fully
implemented host-based firewalls and intrusion detection systems
on their servers and workstations that process US-VISIT
information. CBP has not established centralized log collection
for all CBP servers supporting US-VISIT. Moreover, CBP does not
have fully documented policies and procedures for responding to
security incidents. For example, at the time of our review, CBP
officials stated that policies and procedures for the containment,
eradication, and recovery of incidents were currently under
development. As a result, without consistent detection and
reporting, CBP cannot be assured that it is detecting and handling
incidents in systems supporting US-VISIT in an effective manner.
Implementation of Policies Involving Personally Identifiable
Information^39
In addition to FISMA, federal agencies are subject to privacy laws
aimed at preventing the misuse of personal information. The
Privacy Act of 1974 and the privacy provisions of the E-Government
Act of 2002 contain the major requirements for the protection of
personal privacy by federal agencies. The Privacy Act places
limitations on agencies' collection, disclosure, and use of
personal information maintained in systems of records^40 and
requires that when agencies establish or make changes to a system
of records, they must notify the public by a system of records
notice.^41 The E-Government Act of 2002 strives to enhance
protection for personal information in government information
systems or information collections by requiring that agencies
conduct privacy impact assessments. These privacy impact
assessments include an analysis of how personal information is
collected, stored, shared, and managed in a federal system.
39Personally identifiable information refers to any information about an
individual maintained by an agency, including any information that can be
used to distinguish or trace an individual's identity, such as their name,
social security number, date and place of birth, or biometric records, and
any other personal information which is linked or linkable to an
individual.
^40The act describes a "record" as any item, collection, or grouping of
information about an individual that is maintained by an agency and
contains his or her name or another personal identifier. It also
identifies "system of records" as a group of records under the control of
any agency by the name of the individual or by an individual identifier.
^41A system of records notice is a notice in the Federal Register
identifying, among other things, the type of data collected, the types of
individuals about whom information is collected, the intended "routine"
uses of data, and procedures that individuals can use to review and
correct personal information.
According to OMB guidance, these privacy impact assessments must
analyze and describe how the information will be secured including
administrative and technological controls and should be
current.^42 Further, DHS guidance requires them to describe how
shared information is secured by the recipient and how the
external system's security controls have been addressed to ensure
the security of the information once it is shared. One goal of the
US-VISIT program is to protect the privacy of our visitors.^43
However, privacy documents for systems supporting US-VISIT were
not current or complete. For example, DHS officials told us that
the TECS system of records notice was out of date. In addition,
privacy impact assessments have not been completed for other
US-VISIT systems. For example, CBP did not complete assessments
for two regional field local-area networks,^44 nor was an
assessment approved for TECS.^45
Without fully developing privacy impact assessments and protecting
the confidentiality of personal information in its computer
systems through adequate computer security controls, there is a
heightened risk that disgruntled employees or malicious users
could alter personal information and compromise the
confidentiality, integrity, and availability of US-VISIT data, as
well as the data of other applications on the mainframe.
Conclusions
CBP systems supporting the US-VISIT program were riddled with
significant information security control weaknesses that place
sensitive information--including personally identifiable
information--at increased risk of unauthorized and possibly
undetected disclosure and modification, misuse, and destruction,
and place program operations at increased risk of disruption.
Weaknesses existed in all control areas and computing device types
reviewed. Deficiencies in identification and authentication
controls, authorization controls, boundary protection measures,
physical security, use of cryptography, audit and monitoring
practices, segregation of duties, and configuration assurance
controls exposed CBP's mainframe computer, network infrastructure,
servers, and workstations to insider and external threats. While
CBP has made important progress in implementing the department's
information security program, it has not taken all the steps
necessary to ensure the confidentiality, integrity, and
availability of the information and information systems supporting
the US-VISIT program. Consequently, such information may have been
disclosed to or modified by unauthorized individuals.
^42According to FY 2006 Reporting Instructions for the Federal Information
Security Management Act and Agency Privacy Management, OMB Memo M-06-20,
July 17, 2006, a privacy impact assessment or a system of records notice
is current if that document satisfies the applicable requirements and
subsequent substantial changes have not been made to the system.
^43GAO, Some Progress Made, but Many Challenges Remain on U.S. Visitor and
Immigrant Status Indicator Technology Program, [60]GAO-05-202 (Washington,
D.C.: Feb. 2005).
^44CBP conducted an assessment for two of the field local-area networks
and said that the local area networks did need privacy impact assessments
since personal data was stored in logs; an assessment for another local
area network said that no privacy impact assessment was needed because
information was not stored on the network, to include audit logs.
^45The lack of a TECS PIA was noted in the TECS risk assessment. The DHS
Privacy Office determined that the mainframe on which TECS resides did not
need a PIA.
These weaknesses require immediate attention. Ensuring that
weaknesses affecting CBP's computing resources are promptly
mitigated and that controls are effective to protect US-VISIT
information require senior management support and leadership,
disciplined processes, effective coordination between CBP and
other government organizations, and consistent oversight. Until
DHS and CBP act to mitigate the weaknesses in CBP systems
supporting the US-VISIT program and CBP effectively and fully
implements its information security program, limited assurance
exists that sensitive information will be sufficiently safeguarded
against unauthorized disclosure, modification, and destruction,
and that the US-VISIT program will achieve its goals.
Recommendations for Executive Action
To help the Department effectively and fully implement information
security program activities for CBP systems supporting the
US-VISIT program, we are recommending that the Secretary of
Homeland Security direct the Commissioner, U.S. Customs and Border
Protection to
1. fully characterize risks in risk assessments for
systems supporting US-VISIT program;
2. update the interconnection security agreements in
the TECS security plan;
3. enhance the procedures and documentation for
testing and evaluating the effectiveness of security
controls;
4. ensure remedial action plans address all
significant security vulnerabilities, accurately
report status of remedial actions, and identify
necessary resources for completing actions;
5. fully develop and implement policies and tools for
the timely detection and handling of security
incidents; and
6. update and complete privacy documents for systems
supporting the US-VISIT program.
In a separate report designated limited official use only, we are
making 54 detailed recommendations to the Secretary of Homeland
Security to strengthen information security controls over CBP
systems supporting the US-VISIT program.
Agency Comments
We received written comments on a draft of our report from DHS'
Director of the Departmental GAO/OIG Liaison Office (these are
reprinted in app. I). The director stated that CBP concurs with
our six recommendations and that it has already taken a number of
steps toward mitigating many of our findings. The director also
stated that the department has directed CBP to complete
remediation activities to address each of the recommendations.
As we agreed with your office, unless you publicly announce the
contents of this report earlier, we plan no further distribution
of it until 30 days from the date of this letter. We will then
send copies of this report to the Secretary of the Department of
Homeland Security; the Commissioner of Customs and Border
Protection; the Director of the United States Visitor and
Immigrant Status Indicator Technology Program; the DHS Inspector
General; and other interested congressional committees. We will
also make copies available to others on request. In addition, the
report will be available at no charge on GAO's Web site at
[49]http://www.gao.gov .
If you have any questions regarding this report, please contact
Gregory C. Wilshusen at (202) 512-6244 or Keith A. Rhodes at (202)
512-6412. We can also be reached by e-mail at
[50][email protected] or [51][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 II.
Gregory C. Wilshusen
Director, Information Security Issues
Keith A. Rhodes
Chief Technologist
Appendix I: Comments from the Department of Homeland Security
Appendix II: GAO Contacts and Staff Acknowledgments
GAO Contacts
Gregory C. Wilshusen, (202) 512-6244, [52][email protected] Keith
A. Rhodes, (202) 512-6412, [53][email protected]
Staff Acknowledgments
In addition to the individuals named above, William F. Wadsworth;
Bruce E. Cain; Jason A. Carroll; Lon C. Chin; West E. Coile; Kirk
J. Daubenspeck; Neil J. Doherty; Patrick R. Dugan; Denise E.
Fitzpatrick; Edward M. Glagola Jr.; Kory W. Godfrey; Mustafa S.
Hassan; David B. Hayes; Kaelin P. Kuhn; Vernetta Y. Marquis; Kevin
C. Metcalfe; Jennifer U. Mills; Tammi L. Nguyen; Ronald E. Parker;
David F. Plocher; John A. Spence; Henry I. Sutanto; Amos A.
Tevelow; and Christopher J. Warweg, made key contributions to this
report.
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[61]www.gao.gov/cgi-bin/getrpt?GAO-07-870 .
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Highlights of [62]GAO-07-870 , a report to congressional requesters
July 2007
INFORMATION SECURITY
Homeland Security Needs to Immediately Address Significant Weaknesses in
Systems Supporting the US-VISIT Program
Intended to enhance the security of U.S. citizens and visitors, United
States Visitor and Immigrant Status Indicator Technology (US-VISIT)
program encompasses the pre-entry, entry, status management, and exit of
foreign national travelers who enter and leave the United States at 285
air, sea, and land ports of entry.
GAO was asked to determine whether Department of Homeland Security (DHS)
has implemented appropriate controls to protect the confidentiality,
integrity, and availability of the information and systems used to support
the US-VISIT program. To do this, GAO examined the controls over the
systems operated by Customs and Border Protection (CBP) that support the
US-VISIT program.
[63]What GAO Recommends
GAO recommends that the Secretary of Homeland Security direct CBP to fully
implement information security program activities for systems supporting
the US-VISIT program. In commenting on a draft of this report, DHS stated
that it has directed CBP to complete remediation activities to address
each of the recommendations.
The systems supporting the US-VISIT program have significant information
security control weaknesses that place sensitive and personally
identifiable information at increased risk of unauthorized and possibly
undetected disclosure and modification, misuse, and destruction.
Weaknesses existed in all control areas and computing device types
reviewed. Deficiencies in access controls and other system controls
exposed mainframe computer, network infrastructure, servers, and
workstations to insider and external threats. For example, CBP did not
implement controls to effectively prevent, limit, and detect access to
computer networks, systems, and information. To illustrate, it did not (1)
adequately identify and authenticate users in systems supporting US-VISIT;
(2) sufficiently limit access to US-VISIT information and information
systems; (3) ensure that controls adequately protected external and
internal network boundaries; (4) effectively implement physical security
at several locations; (5) consistently encrypt sensitive data traversing
the communication network; and (6) provide adequate logging or user
accountability for the mainframe, workstations, or servers. In addition,
CBP did not always ensure that responsibilities for systems development
and system production were sufficiently segregated and did not
consistently maintain secure configurations on the application servers and
workstations at a key data center and ports of entry.
These weaknesses collectively increase the risk that unauthorized
individuals could read, copy, delete, add, and modify sensitive
information, including personally identifiable information, and disrupt
the operations othe US-VISIT program. They make it possible for intruders,
as well as government and contractor employees, to bypass or disable
computer access controls and undertake a wide variety of inappropriate or
malicious acts. These risks are not confined to US-VISIT information. The
CBP mainframe and network resources that support US-VISIT also support
other programs and systems. As a result, the vulnerabilities identified in
this report could expose the information and information systems of the
other programs to the same increased risks.
A key reason for these weaknesses is that, although CBP has made important
progress in implementing elements of the department's information security
program, it did not effectively or fully implement essential program
activities. For example, CBP did not fully characterize the risks facing
critical systems, update interconnection security agreements in security
plans, sufficiently test and evaluate security controls, incorporate
required elements in remedial action plans, adequately implement incident
detection and handling procedures, and consistently address privacy
issues. Until DHS and CBP act to mitigate the weaknesses in CBP systems
supporting the US-VISIT program and CBP effectively and fully implements
its information security program, limited assurance exists that the
US-VISIT program will achieve its goal of enhancing the security of U.S.
citizens and its visitors.
References
Visible links
42. http://www.gao.gov/cgi-bin/getrpt?GAO-03-563
43. http://www.gao.gov/cgi-bin/getrpt?GAO-03-1083
44. http://www.gao.gov/cgi-bin/getrpt?GAO-04-586
45. http://www.gao.gov/cgi-bin/getrpt?GAO-05-202
46. http://www.gao.gov/cgi-bin/getrpt?GAO-07-278
47. http://www.gao.gov/cgi-bin/getrpt?GAO-06-404
48. http://www.gao.gov/cgi-bin/getrpt?GAO-07-499T
49. http://www.gao.gov/
50. mailto:[email protected]
51. mailto:[email protected]
52. mailto:[email protected]
53. mailto:[email protected]
54. http://www.gao.gov/
55. http://www.gao.gov/
56. http://www.gao.gov/fraudnet/fraudnet.htm
57. mailto:[email protected]
58. mailto:[email protected]
59. mailto:[email protected]
60. http://www.gao.gov/cgi-bin/getrpt?GAO-05-202
61. http://www.gao.gov/cgi-bin/getrpt?GAO-07-870
62. http://www.gao.gov/cgi-bin/getrpt?GAO-07-870
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