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The Value of =
Documentation: A=20
Useful System Security Plan Template Introduction This paper is intended for those = who may be new=20 to the information security arena and who have been tasked short = order=20 with assembling a system security plan for a civilian agency = Security=20 Certification and Accreditation Package. A Security Certification = and=20 Accreditation Package requires several documents and is not = limited to but=20 may include these: Risk Assessment, Risk Mitigation Plan, System = Security=20 Plan, Certification Test Plan, Certification Test = Report. I used NIST Special Publication = 800-18 as a=20 guide for this paper about the value of system documentation and = systems=20 security plans. I have chosen to provide additional insight to the = guide,=20 and have built a template as a practical extension of the = materials=20 contained in 800-18. The basic purpose of this paper is to address = the=20 value of system documentation and it provides a System Security = Plan (SSP)=20 template that can be put to immediate use in the field. = Why Documentation? One aspect of successfully managing = an IT=20 system is actively protecting it. In order to actively protect a = system,=20 you have to know what it is, what it does, what its weaknesses = are, what=20 potential threats to it exist, and what has or is being done to = mitigate=20 the risks to your data and system (DOJ). Organizations that choose to = passively protect=20 their systems can lose vital institutional knowledge when = something as=20 simple as one mere employee is injured, retires, or follows a = better=20 opportunity. Yet how much more they lose when an employee = willfully=20 destroys data on their way out the door, or when an intruder = alters access=20 logs and creates hidden accounts. These examples illustrate what = can come=20 from what is essentially system negligence. Yet, all of these = attacks on a=20 system’s availability, integrity, and confidentiality could = have been=20 addressed in a preventative manner through the results that come = from=20 having gone through the process of completing thorough system=20 documentation. Are systems really neglected? Funny = you should=20 ask. One of the most common but tragic efforts I have seen for = attempting=20 to get out of doing system documentation is the almost existential = notion=20 that, "if my data isn’t sensitive, then it doesn’t = need protection,=20 right?" Of course, people often take it a step further, and those = in the=20 Federal sector who do so may suddenly find themselves defending = their=20 existence to their Inspector General. Why people don’t = consider the=20 consequences of stating that their system has no data of value on = it=20 puzzles information assurance professionals to this day. The = important=20 point here is not to do it--or you may find yourself trying to = prove that=20 your organizational role is valid and that you really do need your = IT=20 budget. Do people really do this? Ask around. You’ll be=20 surprised. OK. So, what does every manager = really want? To=20 be recognized, promoted, or build an empire of course. How can a = manager=20 arrive at these goals if they don’t have the tools they need = to make=20 effective decisions? There is no legitimate means. This is because = effective decisions cannot be made if what a system is, and what = it does,=20 etc, is not known. Commonly, managers "have not = instituted=20 procedures for ensuring that risks are fully understood and that = controls=20 implemented to mitigate risks are effective" (GAO). Therefore, = protection=20 should be determined by evaluating the sensitivity and criticality = of the=20 information processed, the relationship of the system to the=20 organization’s mission, and the economic value of the = system’s components,=20 among other factors. At this point some may try to = dismiss=20 documenting system security since risk must be accepted as a part = of doing=20 business. While it is true that a decision must be made to proceed = with=20 risk acceptance or risk mitigation, all systems deserve = risk-effective=20 decisions to be made, and this can only be accomplished by having = key=20 information about the system available to the decision maker. = Another hazard of managers not = clearly=20 understanding their systems is that they will rely on = technologists for=20 advice. Being a technologist myself, I can admit that sometimes it = is=20 easier to take technology in search of a mission and to let = technology=20 dictate a system’s requirements, rather than to build in = security from the=20 beginning. Besides, who has time for documentation when you get = new "toys"=20 to work with and "work" is sending you subliminal messages to = leave that=20 boring paperwork stuff alone. Fortunately, times are changing = with the advent=20 of serious e-commerce, but it is still a rare thing for = technologists in=20 general to be rewarded for properly applying security to their = systems.=20 After all, we’re rewarded for how transparently everything = operates, how=20 fast processors can churn, and for how quick we can get that next = software=20 release out, not for bogging the system down by adding encryption = etc., or=20 for filling out forms on the status of your systems. For all of = these=20 reasons, it is clear that efforts should be made to thoroughly = document a=20 system’s security. Since security is historically, = outside of the=20 Department of Defense and financial industries, an afterthought, = it is not=20 uncommon that security requirements will come down through = administrative=20 channels in such a surprising fashion that all to often they leave = bewildered information technologists or project managers wondering = what to=20 do. So What Is A System Security Plan=20 Anyway? Best practices dictate that one of = the best=20 ways to document the protection afforded the system by managerial, = operational, technical, and other means is by creating a system = security=20 plan. This is because a well-done SSP provides a concise location = (OMB) of=20 documented system requirements that can be readily utilized from = the=20 initial phases of a system’s development through its = disposal. SSPs are of particular value = because they=20 address so many security-related facets of a system. In short, the = material in an SSP will help in protecting the confidentiality, = integrity,=20 and availability of the system it is for because it documents the = system’s=20 basic security requirements, the controls in place, planned = controls, the=20 responsibilities of system users, and expected user behavior = (Swanson, 2).=20 These five areas are key areas to document. Documenting the five areas above = provides a=20 very useful concentration of security information—one that = can be used=20 throughout any systems development life cycle phase. The security=20 requirements show developers, managers, and auditors alike, what = the=20 system should be allowed to do or not do. Documenting the controls = in=20 place, or the planned controls in instances of system development = or=20 remediation, identifies specifics about a system’s security. = Putting the=20 responsibilities of system users in writing is vital since you can = create=20 a user policy / announcement that users have to sign that they = have read=20 them. By using this method as an opportunity to inform users about = their=20 security responsibilities, you can also increase their awareness = of=20 information security, as well as provide your organization = recourse for=20 user misbehavior. Security Plan Template = Overview I have created APPENDIX A below as = a guide to=20 drafting a system security plan for new or existing general = support=20 systems. As you may be aware, NIST classifies systems as either = "systems,"=20 "major applications" or "general support systems." Only major = applications=20 and general support systems are required to have system security = plans=20 because generic systems are likely to be included under the = umbrella of=20 one of the former. When looking for detailed = solutions, the NIST=20 Special Publication 800-18 does an excellent job of describing a = framework=20 for a system security plan and should be referenced http://cs= rc.nist.gov/publications/nistpubs/index.html/=20 (NIST). I have chosen to use an adapted=20 fill-in-the-blank approach in order to simplify the process of = adequately=20 documenting a system via a SSP for the anxious information = technologist or=20 project manager; however, I believe that information assurance=20 professionals will also find this document a ready and adaptable = resource.=20 To get the most from the adapted=20 fill-in-the-blank approach, I recommend attempting to first view = each=20 "blank" as though it were an inquiry. For example, under Integrity = Controls I have=20 stated: The procedures for updating = anti-virus=20 signature files are: Procedure X Procedure Y Procedure Z Try asking yourself, "What are our = procedures=20 for updating anti-virus signature files?" Then, as you pause and = answers=20 come flooding to your mind, simply replace ‘Procedure = X’ with the first=20 step of what you or your organization actually does. I have used=20 variations of X, Y, and Z throughout to this template in order to=20 illustrate that more than one response may be = necessary. If answers didn’t come = flooding to your mind,=20 don’t fret. You will find it best to answer each area with = existing=20 policy. If you’re lucky, your security officer or security = program manager=20 has recently updated and published an enterprise information = security=20 handbook filled with the best security policies written in lay = terms. If=20 you’re not so fortunate, you may have to root around in = dusty employee=20 handbooks and surf on your static intranet links until you find at = least=20 some applicable existing policy. Using existing policy simplifies = and=20 hastens coordination issues and ruffles the fewest organizational=20 feathers. The next best way to answer each = blank is with=20 the existing typical organizational or managerial response. If = your=20 typical way of handling things is a functional and accepted = method, then=20 you have it easy. Just put it in writing. "But wait," you may be = thinking,=20 "you want me to document that our friendly termination procedures = involve=20 surprise drop offs of empty boxes to the cubes of employees that = are to be=20 let go by mid-day?" If that’s case, I’d hate to see = your unfriendly=20 termination procedures, but you’ll have to make that = decision. Just=20 remember, others will review this document, so you may wish to = quickly=20 revisit your poor public relations campaign and upgrade your = procedures to=20 something more palatable before the truth gets out. Now what if you come across a blank = that you’ve=20 never dealt with? Simple. Invent a response that you feel a = reasonable and=20 prudent person would accept, and see where it gets you. The real = key to=20 any response is that it is enforceable. The best enforceable = responses are=20 those that are documented and known, and thus the cycle of = committing all=20 things to paper and spreading the word of the value of current = system=20 documentation continues. Allow your trusted peers to review = your initial=20 security plan and ask them for insights. After incorporating their = useful=20 responses, you will probably be asked to submit your security plan = to your=20 organization’s information assurance office. You may find it = in your best=20 interest to create a cover letter for all of those who support = your=20 efforts to sign off on. Be committed to your answers, and = know that=20 when your document is reviewed, it is not you undergoing a = personal=20 confrontation. Rather, the review process is a useful method of = weeding=20 out unnecessary information, examining deficiencies, and shaping = your=20 system security plan into the tool it is meant to be. Because organizations may have a = preferred=20 format (NIH), I have purposely left this SSP template unnumbered = in order=20 to easily accommodate adaptations. You will likely want to create a = cover sheet=20 for your document and include on it the "Name of your = Organization," the=20 acknowledgement "Sensitive Information," an "Organizational Logo," = the=20 title "System Security Plan for System Name / Identification = Number," the=20 current "Date" for versioning purposes, and the statement = "Prepared by,"=20 to identify who to contact for clarification and to give yourself = some=20 credit. Note: The date and the acknowledgement of it containing = sensitive=20 information should be on every page. As you go about gathering = information, avoid=20 generic statements, because they do not provide you with thorough=20 documentation. Also, set specific "shall" dates for things not yet = accomplished. For example, "The procedures for updating anti-virus = signature files shall be listed here by August 31, 2001." Setting = specific=20 dates and avoiding the use of generic "all month" dates will let = you know=20 where you stand and keep your deliverable schedule on = track. On a parting note, remember, a SSP = is a dynamic=20 document reflecting the current security posture of the IT system. = Therefore, as further security related information is acquired and = as=20 system developments occur, updates to the SPP subject areas should = be=20 made. Works Cited: Swanson, Marianne. "Special =
Publication=20
800-18." NIST Computer Security Resource Center (CSRC). December=20
1998. OMB. "Management of Federal =
Information=20
Resources." Circular No. A-130. November 2000. GAO. "Information Security: Serious =
Weaknesses=20
Place Critical Federal Operations and Assets at Risk." GAO / =
AIMD-98-92.=20
September 1998. NIH. "Application / System Security =
Plan=20
Template." NIH. May 1999. DOJ. "Systems Development Life =
Cycle Guidance=20
Document." DOJ / IRM / Appendix C-9. March 2000. APPENDIX A – USEFUL SYSTEM = SECURITY PLAN=20 TEMPLATE COVER SHEET The Cover Sheet should = contain: Name of your =
Organization EXECUTIVE SUMMARY The Executive Summary should=20 contain: Introduction TABLE OF CONTENTS EXECUTIVE SUMMARY SYSTEM IDENTIFICATION MANAGEMENT CONTROLS OPERATIONAL CONTROLS TECHNICAL=20
CONTROLS SYSTEM IDENTIFICATION System Title / System Alias=20 (Acronym) System X (X) System Identification = Number Agency/Corporate = Acronym-Organization=20 Acronym-GS-System Alias-Number-Year Responsible = Organization Agency/Corporate =
Name Information Contacts: System Owner(s) Person =
X System = Administrator(s) Person =
Y1 System Maintenance Person =
Y3 Assignment of Security=20 Responsibility Person =
Z System Operational = Status The following chart depicts the = system(s)=20 covered by this SSP and their operational status:
General System Description /=20 Purpose This system is a General Support=20 System. The purpose of this system is = to… The process flow of the system is = as=20 follows: 1. 2. 3. 4. 5. 6. The following chart depicts = internal and=20 external user organizations and the types of data and processing = they=20 utilize:
Technical System = Environment The system is = located… The system is connected = to… The system’s platform = is… The system’s principle = components=20 are… The system uses… The security software protecting = the system=20 is… System Interconnection / = Information=20 Sharing The following chart depicts = interconnected=20 systems, their unique identifiers, whether they have their own = SSP, and if=20 an MOU has been obtained:
Sensitivity of Information=20 Handled Applicable Laws or Regulations = Affecting the=20 System General Descriptions of Information = Sensitivity The following chart depicts the = criticality of=20 the system based on its basic protection requirements:
MANAGEMENT CONTROLS Risk Assessment and = Management The Risk Assessment methodology = used on the=20 system was / will… The latest Risk Assessment = performed on the=20 system was completed on XXXXX YY, 2001. The next Risk Assessment will = performed on the=20 system no later than XXXXX YY, 2004. Review of Security = Controls The latest independent security = review of the=20 system was completed on XXXX YY, 2001. X performed the security review for = the purpose=20 of Y. The findings of the independent = security review=20 show… As a result of these findings, the = following=20 actions have been / will be taken: Action X Rules of Behavior As the Rules of Behavior will vary = greatly=20 between systems let alone organizations, see NIST Special = Publication=20 800-18 for guidance on satisfying this section. Planning for Security in the Life=20 Cycle The system is in the X phase of the = Life=20 Cycle. As a system’s life cycle will = vary greatly=20 between organizations, see NIST Special Publication 800-18 for = guidance on=20 satisfying this section. Accreditation / Authorize=20 Processing This chart depicts when and who has = requested=20 to operate the system and when and who has given their approval = for system=20 operation:
OPERATIONAL CONTROLS Personnel Controls The following position(s) have = undergone a=20 position sensitivity analysis, and are rated as having High, = Moderate, or=20 Low sensitivity: X Position = High sensitivity =
The following position(s) have not = yet=20 undergone a position sensitivity analysis: Z Position = Sensitivity=20 undetermined The following individuals(s) have = undergone=20 background screening appropriate to their position: Person X The following individuals(s) have = not yet=20 undergone background screening appropriate to their position, but = shall by=20 the date(s) listed below: Person Z – April, 13 200? = (Date in the near=20 future) Using the principle of least = privilege, user=20 access has been limited to the minimum necessary for the following = positions: X Position The critical function(s) that have = been divided=20 among different positions are: X Position = Ability to X The critical function(s) that have = not yet been=20 divided among different positions, but shall be by the date(s) = listed=20 below are: Z Position = Ability to Z1, Z2, = Z3 – Date in=20 the near future User accounts for this system are = requested=20 by… User accounts for this system are = established=20 by… User accounts for this system are = issued=20 by… User accounts for this system are = closed=20 by… The mechanisms in place for holding = users=20 responsible for their actions are: Mechanism X The procedures for friendly = terminations=20 are: Step X The procedures for unfriendly = terminations=20 are: Step X Physical and Environmental=20 Protection Entry and exit of personnel from = areas=20 containing system hardware, supporting systems, and backup media = is=20 restricted by: Restriction X Entry and exit of personnel from = areas=20 containing system hardware, supporting systems, and backup media = is=20 restricted by: Restriction Z The working fire suppression = equipment stored=20 near critical systems is accessible by: Action X, Location X In case of electrical power failure = systems and=20 personnel are protected by: Option X In case of heating / = air-conditioning failure=20 systems and personnel are protected by: Option X In case of potable water failure = personnel are=20 protected by: Option X In case of sewage failure personnel = are=20 protected by: Option X In case of structural collapse, the = systems are=20 protected by: Option X In case of structural collapse, the = systems are=20 protected by: Option X The only plumbing lines that may = endanger the=20 system are located at: Location X In case of plumbing leaks, the = systems are=20 protected by: Option X The greatest risk of the potential = interception=20 of system data comes from Risk X, and has been addressed by = Safeguards X=20 and Y. Mobile and portable systems are = accounted for=20 by: Method Z In case of loss or damage, mobile = and portable=20 systems and the data they contain are protected by: Method X Production / Input and Output=20 Controls The group (help desk) designated to = offer=20 advice and support users is Group X, which can be contacted by the = following methods: Method X The procedures for ensuring = unauthorized=20 individuals cannot read, copy, alter, or steal printed information = are: Step X The procedures for ensuring = unauthorized=20 individuals cannot read, copy, alter, or steal electronic = information=20 are: Step X The procedures for ensuring the = restricted=20 access of sensitive system outputs are: Step X The procedures for ensuring only = authorized=20 individuals can pick up, receive, or deliver input and output = information=20 and media are: Step X The procedures for controlling the = secure=20 transport of system media or output are: Step X The procedures for controlling the = secure=20 mailing of system media or output are: Step X Sensitivity labeling is = accomplished=20 by: Method X The following sensitivity / = handling label(s)=20 are used frequently: Label X Inventory management is = accomplished=20 by: Method X Media storage protection is = accomplished=20 by: Method X in Location X The procedures for sanitizing = electronic media=20 for reuse are: Step X The procedures for destroying = unusable=20 electronic media are: Step X The procedures for shredding or = otherwise=20 destroying sensitive hardcopy are: Step X Continuity of Operations Plan=20 (COOP) The COOP to allow the continuance = of=20 mission-critical functions for this system in case of a = catastrophic event=20 involves the following steps: Step X The full COOP is accessible via the = following=20 personnel / methods: Person X The COOP for this system has been = tested=20 by: Method X The COOP for this system was last=20 tested: Date X The COOP for this system will next = be=20 tested: Date Y The COOP(s) to allow the for all = supporting IT=20 systems and networks are accessible via the following personnel /=20 methods: Person X Formal written emergency operating = procedures=20 are posted at: Location X The personnel knowledgeable of and = trained in=20 the COOP for this system, and their responsibilities = are: Person X, Responsibility =
X The written COOP agreements for = backup=20 processing are with the following points-of-contact and their = respective=20 organizations: Agreement X, Person X and Contact =
Information,=20
Organization X The procedures and frequency of = local backups=20 for this system are: Step X, Daily, Incremental =
Backup Generational backups are securely = stored in the=20 following locations: Incremental Backups for this fiscal =
year,=20
On-site Location X The content of each backup is as=20 follows: Incremental Backups =
contain…data=20
types. Hardware and System Software = Maintenance=20 Controls The normal restrictions on those = who perform=20 maintenance and repair activities are: Restriction X The special procedures to allow for = emergency=20 maintenance and repair activities are: Procedure X The procedures used for items = serviced through=20 off-site maintenance and repairs are: Procedure X The procedures used for maintenance = and repairs=20 via remote maintenance services are: Procedure X The configuration management = procedures used=20 for system / software version control are: Procedure X The configuration management = procedures used=20 for testing system / software components prior to operation=20 are: Procedure X The configuration management = procedures used to=20 ensure continuity of operations plans and other associated data=20 are: Procedure X The configuration management = procedures control=20 the usage of test data are: Procedure X The configuration management = procedures control=20 the usage of live data are: Procedure X The organizational policies against = the illegal=20 use of copyrighted software are… Integrity Controls The procedures for updating = anti-virus=20 signature files are: Procedure X The password crackers / checkers = used to test=20 password strength are: Software X The integrity verification programs = used to=20 look for data tampering, errors, etc are: Software X The intrusion detection tools used = to identify=20 attacks and do trend analysis are: Software X The system performance monitoring = tools used to=20 analyze system performance are: Software X The procedures used for system = penetration=20 tests are: Procedure X The message authentication and = non-repudiation=20 feature of the system is: Feature X Documentation The following chart depicts the = types, POCs,=20 and locations of system documentation:
Security Training, Education, and=20 Awareness The procedures for ensuring that = employees and=20 contractor personnel have been provided system security training=20 are: Procedure X System security training has been = provided to=20 the following individuals(s): Person X The procedures for ensuring that = employees and=20 contractor personnel are educated in how to recognize and report = system=20 security incidents are: Procedure X System security awareness has been = promoted by=20 the use of the following methods: Method X The procedures for measuring the = effectiveness=20 of system security awareness promotion methods are: Procedure X Incident Response = Capability The procedures for reporting system = security=20 incidents are: Procedure X The person(s) who receive and = respond to vendor=20 alerts / advisories are: Person X The measures planned or in place to = prevent=20 system security incidents are: In Place Measure X TECHNICAL CONTROLS Authentication The authentication methods for the = system=20 are: Method X Passwords for the system shall meet = the=20 following requirements: Requirement X The procedures for verifying that = all default=20 authentication mechanism have been disabled or changed = are: Procedure X Identification The identification methods for the = system=20 are: Method X Logical Access = Controls The controls in place to authorize = the=20 activities of users and system personnel are: Control X The controls in place to restrict = the=20 activities of users and system personnel are: Control X The controls in place to detect = unauthorized=20 activities of users and system personnel are: Control X Prior to login, the warning banner = for this=20 system states: Audit Trails System audit trails record the = following=20 events: Auditable Event X The procedures for ensuring the = confidentiality=20 of audit trail data are: Procedure X System audit trail data is reviewed = by Person X=20 every Z. System audit trail data is reviewed = by Person Y=20 every Z1. |
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to top of page |=20 to = Security=20 Policy Issues | to = Reading=20 Room Home
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