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  • 1. Federal Information Security Management Act An IG Perspective FEBRUARY 2, 2004 Presented To: The President’s Council on Integrity and Efficiency Information Technology Round Table Presented By: Russell A. Rau, Assistant Inspector General for Audits Office of Inspector General Federal Deposit Insurance Corporation
  • 2. Agenda
    • FISMA: An IG Approach
    • 2004 Issues
    • Future Issues
    • Challenges Facing IG Auditors
    • New FISMA Working Group
    • Questions and Answers
  • 3.
    • Multi-year strategy for auditing the agency information security program
      • Strategy addresses the security program framework defined by FISMA
      • Audits conducted throughout the year are risk-based and support the multi-year strategy
    • FISMA evaluation lead by in-house staff
    • Contractor supports IG work by testing selected IT technical controls
    FISMA: An IG Approach
  • 4. FISMA: An IG Approach
    • 2002
    • Physical Security
    • Contractor Security
    • Capital Planning
    • 2003
    • Network Security (multiple reviews)
    • Incident Response
    • Patch Management
    • Risk Assessment
    • Personnel Security
    • IT Strategic Planning
    • Contractor Security Follow-up
    Targeted Audits Supporting FISMA
    • 2004
    • Public Key Infrastructure
    • Disaster Recovery
    • Data Sensitivity
    • Physical Security
    • Network Perimeter Security
    • Capital Planning & Investment Control
    • Outside Agency Connections
    • Configuration Management
  • 5.
    • Evaluation Scope and Methodology
    • Government Auditing Standards
    • Reliance on prior audit and evaluation reports
    • Independent testing and evaluation procedures
    • Identified 10 key management controls associated with successful information security programs
    • Key management controls based on federal laws, regulations, and guidelines
    • Key management controls assessed using a traffic light scorecard tool
    FISMA: An IG Approach
  • 6.
    • Government organizations such as GAO, OMB, and NIST have identified fundamental management controls needed for effective information security.
    • These management controls are abstracted from long-standing requirements found in statutes, policies, and guidance. They cover topics such as:
          • Risk Management
          • Security Control Reviews
          • Contingency Planning
          • Access Controls
          • Incident Response
    FISMA: An IG Approach
  • 7.
    • Fundamental s ecurity management principles and controls can be found in:
      • NIST SP 800-26, Security Self-Assessment Guide for Information Technology Systems
      • NIST SP 800-14, Generally Accepted Principles and Practices for Securing Information Technology Systems
      • NIST SP 800-12, An Introduction to Computer Security: The NIST Handbook
      • GAO Executive Guide, Information Security Management: Learning From Leading Organizations
      • FISMA and OMB Circular No. A-130 Appendix III
    FISMA: An IG Approach
  • 8. FISMA: An IG Approach Overall Assessment Capital Planning and Investment Control (C.4) Security Training (C.3) Security Oversight (A.4, B.2, & C.2) Contractor and Outside Agency Security (A.2a-b) Information Security Risk Management (C.1) Computer Security Incident Response (B.8 & B.9) Protection of Critical Assets and Operations (B.7) Integration of Security Activities (B.5 & B.6) Security Performance Measures (B.3 & B.4) Security Responsibilities and Authorities (B.1) Implementation of Controls Establishment of Controls Management Control Area
  • 9. FISMA: An IG Approach
    • Scorecard assessments based on assurance of adequate security:
    •  Green (Reasonable Assurance)
    •  Yellow (Limited Assurance)
    •  Red (Minimal/No Assurance)
    • Assessments require professional judgment
    • Scorecard provides a simple and effective method to communicate complex results
    • Management actions to address scorecard results
      • Performance measures to improve FISMA ratings
      • Established a subcommittee of the Audit Committee
      • “ Getting to Green” Initiative
  • 10.
    • Leveraging Agency Reviews
      • Placing greater reliance on CIO and agency program reviews
      • Providing independent assurance of agency FISMA submissions
    • Integrating FISMA evaluation and financial statement audit work
      • Relying on FISMA results to obtain an understanding of internal controls
      • Planning financial statement audit work based on FISMA results
    FISMA 2004 Issues
  • 11.
    • Contractor Security
      • Auditing major contractors that service multiple federal agencies
      • Verifying minimum security requirements of contractors, such as security planning, training, etc.
    • Enterprise Architecture Security Implications
      • Ensuring major IT projects use security solutions that comply with the agency enterprise architecture
    • Data Sensitivity
      • Categorizing data
      • Protecting sensitive data
    FISMA 2004 Issues
  • 12.
    • Quantifying the Impact of Security Weaknesses
      • Considering the cost-benefit of proposed security enhancements
      • NIST FIPS 199 and Special Publication 800-60
    • Certification and Accreditation (NIST Special Publication 800-37)
    • Verifying the effectiveness of security controls required in federal information systems (NIST Special Publication 800-53A)
    FISMA 2004 Issues
  • 13.
    • Timing of FISMA and Accountability Reports
    • Interagency Issues
      • Federal Bridge (Authentication and Encryption)
      • Federal Enterprise Architecture
      • Servicers that cross agency lines
    Future FISMA Issues
  • 14.
    • How much audit work is enough?
    • How much is too much?
    • We can’t fully evaluate everything every year!
    • At FDIC, we found a balance through a multi-year
    • strategy of performance auditing.
    Challenges Facing IG Auditors
  • 15.
    • Changing Criteria
    • Planned revisions to OMB A-130
    • Recently published NIST Special Publications:
    • 800-50, Building an IT Security Awareness and Training Program
    • 800-42, Guideline on Network Security Testing
    • 800-36, Guide to Selecting IT Security Products
    • 800-35, Guide to IT Security Services
    • 800-64, Security Considerations in the Information SDLC
    • And more to come…
    • Draft 800-53, Recommended Security Controls for Federal Information Systems Draft 800-37, Guide for the Security Certification and Accreditation of Federal Information Systems                      
    • Impact of new technology, such as wireless communications explosion
    Challenges Facing IG Auditors
  • 16.
    • Impact of major events, such as the focus on disaster recovery following 9/11
    • Inconsistent application of standards
      • How does your agency define an information system?
      • What constitutes a material weakness?
      • How does your agency categorize information and information systems?
    • Growing importance of IG auditors to be “technically capable” and possess professional certifications
    Challenges Facing IG Auditors
  • 17.
    • Established for the IG community under the Federal Audit Executive Council
    • Promotes interagency coordination of information security and evaluation requirements established by FISMA
      • FISMA update conferences and training
      • Sharing lessons-learned
      • Interacting with OMB, NIST, CIO Council and GAO
      • Coordinating on issues and initiatives that cross agency lines
      • For more information, contact Judy Hoyle at (202) 416-4088 or jhoyle@fdic.gov.
    FISMA Working Group
  • 18. Questions and Answers