How Safe is Your States Data? Virginias Common-Sense approach to Assessing Security.

How Safe is Your State’s Data?

Virginia’s

Common-Sense

approach to

Assessing Security

Auditor of Public Accounts

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Virginia’s Common-Sense Approach to Assessing Security

• Why did we choose to assess the Commonwealth of Virginia’s systems and data security?

• What was the timeframe from inception to completion?

• What approach did we use to gather the data?

• How did we evaluate the data?


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Virginia’s Common-Sense Approach to Assessing Security

• How did we report the results?

• What were the lessons learned and what would we have done differently?

• What was the response to the report we issued?

Virginia’s IT Governance

• Virginia has had information technology security standards since 1990

• Creation of Virginia Information Technologies Agency (VITA) in 2003

• Commonwealth’s Chief Information Officer is responsible for information technology security

Virginia’s IT Governance

• VITA is responsible for information technology security audits, however they had not been doing them!– Funding issues– Efforts focused on Northrop Grumman public

private partnership for IT infrastructure


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Why did we choose to assess the Commonwealth of Virginia’s systems and data security?

• Security Breaches• Virginia Organization• Jan. 10, 2005 – George Mason University (Fairfax, VA) Names, photos, and

Social Security numbers of 32,000 students and staff were compromised because of a hacker attack on the university’s main ID server.

• Public Organization• On May 22, 2006, the U.S. Department of Veterans Affairs issued a statement

that one of their analyst’s laptops was stolen containing 26.5 million names, social security numbers, dates of birth, and health records of active and retired veterans and spouses.

• Private Organization• Financial services company ING had a laptop stolen from the Washington

home of one of its employees on June 12, 2006 containing sensitive data, such as social security numbers, of 13,000 District of Columbia employees and retirees.


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Why did we choose to assess the Commonwealth of Virginia’s systems and data security?

• Virginia General Assembly passed Senate Joint Resolution 51 (SJR51)

• Which basically said “APA you will assess the health of the security of the Commonwealth’s data.”

APA Audits

• We had been covering IT security related to our financial and performance audits for some time

• We had been issuing findings related to IT security in individual audit reports

• Interpretation of SJR 51 was that we would review security of all data (not just financial or data that resides in a database)


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What was the timeframe from inception to completion?

• Senate Joint Resolution 51 passed by House on March 9, 2006

• Checklist developed July 18, 2006• Pilot study completed August 10, 2006• Final agency report received October 23,

2006• Report issued December 1, 2006


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What approach did we use to gather the data?

• We developed a Checklist/Questionnaire based on current Commonwealth of Virginia Security Standards and Industry Best Practices (ISO17799, FISCAM, CobiT, and NIST)


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Industry Best PracticesISO 17799

This International Standard establishes guidelines and general principles for initiating, implementing, maintaining, and improving information security management in an organization.


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Industry Best PracticesFederal Information System Controls

Audit Manual (FISCAM)

This manual describes the computer-related controls that auditors should consider when assessing the integrity, confidentiality, and availability of computerized data. It is a guide applied by GAO primarily in support of financial statement audits.


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Industry Best PracticesControl Objectives for Information

and related Technology (CobiT)• “Owned” by the IT Governance Institute whose

goal is to advance international thinking and standards in directing and controlling an enterprise’s information technology

• Provides good practices across a domain and process framework and presents activities in a manageable and logical structure

• CobiT’s good practices represent the consensus of experts


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Industry Best PracticesNational Institute of Standards and Technology

(NIST)

• The Information Technology Laboratory (ITL) at NIST provides US measures and standards framework for technology

• Responsibilities include the development of management, administrative, technical, and physical standards and guidelines for federal information systems

• ITL reports its research, guidelines and outreach efforts in the Special Publication 800 series


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Industry Best PracticesNational Institute of Standards and Technology

An example from NIST Special Publication 800-26

Specific Control Objectives and Techniques

Risk Management OMB Circular A-130, III1.1 Critical Element: Is risk periodically assessed?1.1.1 Is the current system configuration documented,

including links to other systems? NIST SP 800-181.1.2 Are risk assessments performed and documented on a

regular basis or whenever the system, facilities, or other conditions change? FISCAM SP-1

1.1.3 Has data sensitivity and integrity of the data been considered? FISCAM SP-1 From Appendix page A-3


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Industry Best PracticesAPA’s adaptation of the same question

An example from APA Auditor Core Checklist

• Has the agency completed and documented a Risk Assessment (RA) relating to its IT infrastructure?

• Is the RA reviewed at least annually to check compliance with the Commonwealth of Virginia security standard?

• Is the RA updated at least every three years?• Does the agency require all components of its

IT infrastructure to be rated in the RA?


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• Checklist/Questionnaire addressed four major areas:– Security Management Structure– Data protection, integrity, availability and

confidentiality– IT System Configuration and change

management– Monitoring and Logging


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• Checklist/Questionnaire was distributed to a select (pilot) group of nine state agencies and institutions:– Based on diversity in terms of number of staff

and size of budget (included both large and small agencies and higher education institutions)


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• A core group of Audit Directors and Senior Audit staff members were identified and trained on the checklist and how to interpret/evaluate results

• This included staff from non-IT related teams within the office


• Approach was to test for the existence of IT policies and procedures

• IT related teams developed the checklist (identifying best practices)

• Do not need to be an IT expert to evaluate the existence of policies and procedures identified in the checklist


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• After the pilot group responded to the checklist:– Checklist/Questionnaire was revised to ensure

clarity– An APA audit staff member was assigned to

each agency– Mass distribution to all agencies/institutions

(104 agencies including judicial and legislative branch)


• Agencies were given five business days to complete the checklist/questionnaire and supply supporting documentation

• Once the documentation was received by APA, two reviews were done one by the assigned auditor second by an a member of the Information

Systems Security Team


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• Once the initial review was completed – Agency was given two additional days to

respond to those questions where the APA determined the documentation to be inadequate

– Mandatory participation was assured by Executive Order


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• Security was achieved by either hand delivery of the checklist to/from the agency

• Or, the APA provided a secure FTP site which could be used by the agencies to upload/download the checklist and supporting documentation


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How did APA evaluate the data?

• Each question was reviewed for appropriate policies and/or procedures

• There were 146 questions on each checklist

• Data was entered into an Access Database for analysis


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• Eleven of the 146 questions were identified as key evaluation criteria

• Four of the eleven questions were titled the Big Four and included:– Business Impact Analysis

– Risk Assessment

– Business Continuity Plan

– Disaster Recovery Plan


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The Questions that APA considered as Key Performance Indicators (KPIs)

1. Does the organizational structure include the assignment of an Information Security Officer (ISO)?

2. Does the agency have a Security Awareness Training program?

3. Has the agency completed and documented a Risk Assessment relating to its IT infrastructure?

4. Does the agency have a documented Business Impact Analysis?


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• The Questions that APA considered as KPIs5. Does the agency have a documented Business

Continuity Plan? 6. Does the agency have a documented Disaster

Recovery Plan?7. Does the agency have policies and procedures for

approving logical access? 8. Are users required to be authenticated for access to

all systems and are exceptions approved by management and have risks of those exceptions been evaluated and accepted?


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• The Questions that APA considered as KPIs 9. Are there policies and procedures regarding password

controls?

10. Does all the critical and sensitive assets have the appropriate physical safe guards in place to protect against unauthorized access and is it documented who approves these controls?

11. Does the Agency monitor their systems, applications and databases?


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controls?




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controls?




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• Final evaluation categories were:– Non-Existent (did not have any of the Big Four

checked as yes)– Inadequate (had at least one of the Big Four but

did not have all eleven checked as yes)– Adequate (had all eleven checked yes)


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How did APA report the results?

• Formal report to the General Assembly and to the Governor

• Posted to the Auditor of Public Accounts website http://www.apa.virginia.gov/

• We structured the report to reflect history, current practices, best practices and recommendations

http://www.apa.virginia.gov/


• Some parts of the report were written during the time the checklists were being completed and evaluated– History– Current practices– Best practices


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• The history included a brief description of the Virginia information technology structure

• An introduction, as well as, a citizens perspective were included


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• The current practices included executive branch agencies and higher educational institutions only

• The current practice also included the security standards, policies and procedures in place at the time of the survey


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• APA made four recommendations:1) VITA should develop a plan to communicate

infrastructure information and standards to agencies that it supports Provide assistance and expertise to agencies Assume responsibility for ensuring IT

infrastructure meets agencies’ needs and is secure


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• APA made four recommendations:2) The General Assembly may wish to consider

granting the Commonwealth’s Chief Information Officer authority over the judicial and legislative information security programs


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• APA made four recommendations:3) The CIO and Information Technology

Investment Board should consider supplementing the Commonwealth’s security standard with the additional processes (industry best practices) identified in this report


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• APA made four recommendations:4) The Commonwealth needs to adopt a strategy

to provide sufficient resources to develop a proper information security plan Need to utilize a central resource such as VITA to

assist small to medium sized agencies that do not have sufficient internal resources to develop a plan


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• Then of course we added in all of the graphics which showed how many were adequate (21), inadequate (66), and non-existent (17)

• We added the checklist in its entirety

• We added the Best Practice comparisons


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What were the lessons learned and what would we have done

differently?• Checklist questions should all be phrased so

that a positive answer is always “YES”• We focused on the existence of policies and

procedures, to follow up we would expand this to include implementation

• We learned that our approach “to not identify the critical questions in advance” was a crucial decision and the right one

How have we used the report?

• Using results as a baseline in audit planning

• Where adequate, we can incorporate tests to ensure policies and procedures have been implemented

• Where inadequate, we can follow up on agencies efforts to address issues


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What was the response to the report we issued?

• New Legislation

• New Executive Orders

• Improved Commonwealth Standards, Policies and Procedures

• Increased awareness


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Va. report: Sensitive data put at riskAuditor says most state agencies have inadequate, porous security programsBY PETER BACQUE, TIMES-DISPATCH STAFF WRITER, Dec 13, 2006

• The majority of Virginia government agencies are doing an unacceptable job of protecting the huge amounts of sensitive information entrusted to them, according to a state report.

• Of 104 state agencies and institutions surveyed by the Auditor of Public Accounts, 80 percent had inadequate security programs, the report said.


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Virginia Bill Would Require Notice When Personal Data Is Lost or Stolen

By Larry O'Dell January 16, 2007

• Two Virginia lawmakers said this week that they will introduce legislation requiring government agencies and businesses to notify Virginians if their personal information is lost or stolen.

• Brink also noted that an investigation by Virginia's Auditor of Public Accounts last year found that a majority of state agencies are doing an unacceptable job protecting citizens' private information.


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Virginia Governor Signs Consumer Privacy, Security OrdersJan 09, 2007 News Release

• Kaine signed Executive Order 43 (2007) directing Virginia's Secretary of Technology, Aneesh Chopra, to oversee efforts to examine state government data security policies and to ensure that they are enforced. The Executive Order follows a recent report from the Virginia Auditor of Public Accounts that concluded a majority of state government agencies in Virginia could do more to protect personal consumer information.


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Contact Information

J Kenneth Magee (804) 225-3350 Ext [email protected]

Staci Henshaw (804) 225-3350 Ext [email protected]

If you want a copy of the checklist please leave me a business card and write CHECKLIST on the back of it.

mailto:[email protected]

mailto:[email protected]


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QUESTIONS

Thank you!

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How Safe is Your States Data? Virginias Common-Sense approach to Assessing Security.

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