Information Security: National Archives and Records Administration Needs to Implement Key Program Elements and Controls
Released: 2010-10-27T00:00:00

Letter

Background

Information security is a critical consideration for any organization reliant on information technology (IT) and especially important for government agencies, such as NARA, 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. Although this expansion has created many benefits for agencies in achieving their missions and providing information to the public, it also exposes federal networks and systems to various threats.

Without proper safeguards, systems are unprotected from attempts by 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. Over the past few years, federal agencies have reported an increasing number of security incidents, many of which involved sensitive information that has been lost or stolen, including personally identifiable information, which has exposed millions of Americans to the loss of privacy, identity theft, and other financial crimes.

NARA Is a Key Steward of Federal Records

NARA is the nation’s record keeper. It was created by statute as an independent agency in 1934. On July 1, 1949, the Federal Property and Administrative Services Act transferred the National Archives to the General Services Administration, and its name was changed to National Archives and Records Services. It attained independence again as an agency in October 1984 (effective April 1, 1985) and became known as the National Archives and Records Administration. NARA’s mission is to ensure continuing access to essential documentation of the rights of American citizens and the actions of their government. NARA also publishes the Federal Register, stores classified materials, and plays a role in the declassification of these classified records.

The Archivist of the United States is NARA’s chief administrator and has responsibilities that include providing federal agencies with guidance and assistance for records management and establishing standards for records retention. The Archivist also has overall responsibility for ensuring the confidentiality, integrity, and availability of the information and information systems that support the agency and its operations. The Assistant Archivist for Information Services has the responsibilities of NARA’s Chief Information Officer.

In fiscal year 2009, NARA’s appropriation was about $459 million, while its fiscal year 2010 appropriation is about $470 million. NARA is composed of six major divisions (see table 1) that include 44 facilities such as the headquarters locations in Washington, D.C., and College Park, Maryland; presidential libraries; and regional archives nationwide.

NARA Relies on Information Systems to Accomplish Its Mission

NARA depends on a number of key information systems to conduct its daily business functions and support its mission. These systems include networks, telecommunications, and specific applications. As of fiscal year 2009, NARA reported having 39 IT systems and 4 externally hosted systems. According to NARA, as part of its key transformation initiative, in 2001 the agency responded to the challenge of preserving, managing, and assessing electronic records by beginning the development of the modern Electronic Records Archives (ERA) system. This major information system is intended to preserve and provide access to massive volumes of all types and formats of electronic records, independent of their original hardware or software. NARA plans for the system to manage the entire life cycle of electronic records, from their ingestion through preservation and dissemination to customers. We have previously made numerous recommendations to NARA to improve its acquisition and monitoring of the system.

Table 2 lists examples of key NARA systems.

The Office of Information Services at the Archives II facility provides centralized management and control of NARA’s IT resources and services, including NARANET, the primary general support system of NARA. As shown in figure 1, NARANET is centrally located at Archives II and connects to other government and academic entities. NARANET is extended to field sites via a private network, operated by a service provider. In addition, at locations where the public has research access, NARA provides access to the Internet through the use of public access computers.

NARA’s Information System Security Program

The Federal Information Security Management Act of 2002 (FISMA) requires each federal agency to develop, document, and implement an requires each federal agency to develop, document, and implement an agencywide information security program to provide security for the agencywide information security program to provide security for the information and information systems that support the operations and information and information systems that support the operations and assets of the agency, including those provided or managed by other assets of the agency, including those provided or managed by other agencies, contractors, or other sources. FISMA requires the Chief agencies, contractors, or other sources. FISMA requires the Chief Information Officer or comparable official at federal agencies to be Information Officer or comparable official at federal agencies to be responsible for developing and maintaining an information security responsible for developing and maintaining an information security program. program.

The Office of Information Services centrally administers NARA’s IT The Office of Information Services centrally administers NARA’s IT security program at the Archives II facility. The Assistant Archivist for security program at the Archives II facility. The Assistant Archivist for Information Services, who also serves as the Chief Information Officer Information Services, who also serves as the Chief Information Officer (CIO), is the head of the Office of Information Services. As described in (CIO), is the head of the Office of Information Services. As described in table 3, NARA has designated certain senior managers or divisions at table 3, NARA has designated certain senior managers or divisions at headquarters to fill the key roles in IT security designated by FISMA and headquarters to fill the key roles in IT security designated by FISMA and agency policy. agency policy.

FISMA also requires the National Institute of Standards and Technology (NIST) to provide standards and guidance to agencies on information security. NARA has a directive in place to establish its policy and guidance for information security, delineate its security program structure, and assign security responsibilities.

Control Weaknesses Threaten Record Retention

NARA has taken steps to safeguard the information and systems that support its mission. For example, it has developed a policy for granting or denying access rights to its resources, employs mechanisms to prevent and respond to security breaches, and makes use of encryption technologies to protect sensitive data.

However, security control weaknesses pervaded NARA’s systems and networks, thereby jeopardizing the agency’s ability to sufficiently protect the confidentiality, integrity, and availability of its information and systems. These deficiencies include those related to access controls, as well as other controls such as configuration management and segregation of duties. A key reason for these weaknesses is that NARA has not yet fully implemented its agencywide information security program to ensure that controls are appropriately designed and operating effectively. These weaknesses could affect NARA’s ability to collect, process, and store critical information and records, and protect that information from risk of unauthorized use, modification, and disclosure.

Weaknesses in Other Controls Increase Risk

In addition to access controls, other important controls should be in place to ensure the confidentiality, integrity, and availability of an organization’s information. These controls include policies, procedures, and techniques for securely configuring information systems, sufficiently disposing of media, implementing personnel security, and segregating incompatible duties. Weaknesses in these areas increase the risk of unauthorized use, disclosure, modification, or loss of sensitive information and information systems supporting NARA’s mission.

Configuration Management Controls Were Not Sufficient

One of the purposes of configuration management is to establish and maintain the integrity of an organization’s work products. It involves identifying and managing security features for all hardware, software, and firmware components of an information system at a given point and systematically controlling changes to that configuration during the system’s life cycle. By implementing configuration management and establishing and maintaining baseline configurations and monitoring changes to these configurations, organizations can better ensure that only authorized applications and programs are placed into operation. NARA policy requires the most restrictive mode possible of the security settings of information technology products. NIST standards state and NARA policy requires system changes to be controlled. Patch management is an additional component of configuration management, and is an important factor in mitigating software vulnerability risks. Up-to-date patch installation can help diminish vulnerabilities associated with flaws in software code. NIST states that organizations should promptly install newly released security relevant patches, service packs, and hot fixes and test them for effectiveness and potential side effects on the organization’s information systems.

NARA had not securely configured several of its systems. For example, network configurations were not always restricted in accordance with best practices; additionally, Web applications and operating systems were not always restricted in accordance with NIST guidance.

While NARA has maintained and tracked configuration changes for its ERA system, it has not consistently documented the status of those changes. NARA documented, maintained, and tracked approvals for ERA’s system change requests in its meeting minutes as well as in a system for managing those change requests, but the information in meeting minutes and the change repository were inconsistent. For example, change requests agreed to in meeting minutes from October 2009 to March 2010 did not always match those entered in the repository storing those changes. Specifically, some change requests were approved for implementation in the meeting, but were listed in the repository as closed. Others were reflected as being on hold, but were actually listed as canceled in the repository. According to ERA configuration management staff, these inconsistencies exist because the configuration control board status represents a single point in time of each change request. Subsequent changes to the system related to each change request are handled by release management staff. Therefore, the status in the repository will continue to change. Configuration management staff have the responsibility to document updates to changes in status at various points in the process.

In addition, NARA had not implemented an effective patch management program for the systems we reviewed. For example, patches had not been consistently applied to critical systems or applications in a timely manner. Specifically, several critical systems had not been patched or were out of date, some of which had known vulnerabilities. Additionally, NARA used out-of-date or unsupported software and products in some instances.

As a result of these control deficiencies, increased risk exists that the integrity of NARA systems could be compromised.

NARA Did Not Consistently Test Equipment Used to Sanitize Media

Media destruction and disposal is key to ensuring confidentiality of information. Media can include magnetic tapes, optical disks (such as compact disks), and hard drives. Organizations safeguard used media to ensure that the information they contain is appropriately controlled. Media that is improperly disposed of can lead to the inappropriate or inadvertent disclosure of an agency’s sensitive information or the personally identifiable information of its employees and customers. NARA uses degaussers to remove sensitive information from hard drives and tapes before reuse or destruction. This equipment should then be certified that it was tested and that it performed correctly. NIST recommends that organizations test sanitization equipment and procedures to verify correct performance. NARA’s policy for protection of media requires that sanitization equipment be tested annually.

However, NARA has not always ensured that equipment used for removing sensitive information was tested annually. For example, while the degausser located at one location was certified annually, one at another location was not. Specifically, one degausser was certified on January 2010, while the other had not been certified since July 2008, about 20 months prior to our on-site visit. By not testing and certifying its degausser, NARA has reduced assurance that the equipment is performing according to certified requirements.

Personnel Security Controls Are in Place

The greatest harm or disruption to a system comes from the actions, both intentional and unintentional, of individuals. These intentional and unintentional actions can be reduced through the implementation of personnel security controls. According to NIST, personnel security controls help organizations ensure that individuals occupying positions of responsibility (including third-party service providers) are trustworthy and meet established security criteria for those positions. For employees and contractors assigned to work with confidential information, confidentiality, nondisclosure, or security access agreements specify required precautions, acts of unauthorized disclosure, contractual rights, and obligations during employment and after termination. NARA’s security policy for personnel screening states that the type of investigation is based on the sensitivity of the position to be held.

NARA conducted the appropriate background investigations for the employees and contractors we reviewed. These individuals also had appropriate nondisclosure agreements signed when applicable to their position. However, at one location contractors had not signed nondisclosure agreements for the ERA system. NARA staff acknowledged the issue and subsequently had the contractors sign the nondisclosure agreements.

Incompatible Duties Were Not Always Effectively Segregated

Segregation of duties refers to the policies, procedures, and organizational structures that help ensure that no single individual can independently control all key aspects of a process or computer-related operation and thereby gain unauthorized access to assets or records. Often, organizations achieve segregation of duties by dividing responsibilities among two or more individuals or organizational groups. This diminishes the likelihood that errors and wrongful acts will go undetected, because the activities of one individual or group will serve as a check on the activities of the other. Effective segregation of duties includes segregating incompatible duties and maintaining formal operating procedures, supervision, and review. 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. For systems categorized as high or moderate impact, NIST states that incompatible duties should be segregated, such as, by not allowing security personnel who administer system access control functions to administer audit functions. NARA also has a policy requiring segregation of duties.

NARA did not always implement effective segregation of duties controls. For example, two staff members were each assigned security and system administration roles and responsibilities, as either a primary or backup for the ERA system (a high impact system). In addition, those individuals had privileges that allowed them to delete logs generated by the system used for auditing and logging security events. According to NARA staff, periodic reviews of the administrators’ access were performed using checklists that require administrators to review each other’s access activities. However at the time of our review, NARA had not documented its oversight process to ensure controls for separation of duties were implemented appropriately. As a result, NARA may face an increased risk that improper program changes or activities could go unnoticed.

NARA Has Not Fully Implemented All Elements of Its Information Security Program

A key reason for the weaknesses in information security controls intended to protect NARA’s systems is that the agency has not yet fully implemented its agencywide information security program to ensure that controls are effectively established and maintained. FISMA requires each agency to develop, document, and implement an information security program that, among other things, includes periodic assessments of the risk and the magnitude of harm that could result from the unauthorized access, use, disclosure, disruption, modification, or destruction of information and information systems; policies and procedures that (1) are based on risk assessments, (2) cost- effectively reduce risks, (3) ensure that information security is addressed throughout the life cycle of each system, and (4) ensure compliance with applicable requirements; plans for providing adequate information security for networks, facilities, security awareness training to inform personnel of information security risks and of their responsibilities for complying with agency policies and procedures, as well as training personnel with significant security responsibilities for information security; periodic testing and evaluation of the effectiveness of information security policies, procedures, and practices, which is to be performed with a frequency depending on risk, but no less than annually, and which includes testing the management, operational, and technical controls for every system identified in the agency’s required inventory of major information systems; a process for planning, implementing, evaluating, and documenting remedial action to address any deficiencies in its information security policies, procedures, or practices; procedures for detecting, reporting, and responding to security incidents; plans and procedures to ensure continuity of operations for information systems that support the operations and assets of the agency.

Although NARA has developed and documented a framework for its information security program, key components of the program have not been fully or consistently implemented.

NARA Developed Risk Assessments but Inconsistently Implemented Risk-Related Procedures

In order for agencies to determine what security controls are needed to protect their information resources, they must first identify and assess their information security risks. FIPS publication 199 provides risk-based criteria to identify and categorize information and information systems based on their impact to the organization’s mission. In addition, the Office of Management and Budget (OMB) states that a risk-based approach is required to determine adequate security, and it encourages agencies to consider major risk factors, such as the value of the system or application, threats, vulnerabilities, and the effectiveness of current or proposed safeguards. By increasing awareness of risks, these assessments can generate support for policies and controls. NIST states that organizations should also assess physical security risks to their facilities when they perform required risk assessments of their information systems. Federal standards require that NARA conduct vulnerability risk assessments at least every 3 years for the buildings and facilities we visited.

NARA has developed and conducted risk assessments, but has not consistently documented risk or assessed risk in a timely manner at its facilities. For example, NARA had developed risk assessments for all 10 of the systems in our review, but other system documentation for 4 of the 10 systems cited FIPS 199 impact levels that did not match those listed in NARA’s systems inventory. Documents for 3 systems reflected impact ratings higher than those listed in the systems inventory and the fourth one reflected a lower rating. Similarly, while NARA had conducted physical security risk assessments for the sites we reviewed, several had not been conducted within the required 3-year time frame. As a result, NARA may not have assurance that adequate controls are in place to protect its information and information systems.

NARA’s Policies and Procedures Were Not Always Consistent with Federal Guidance

Another key element of an effective information security program is to develop, document, and implement risk-based policies, procedures, and technical standards that govern security over an agency’s computing environment. FISMA requires agencies to develop and implement policies and procedures to support an effective information security program. If properly implemented, policies and procedures should help reduce the risk that could come from unauthorized access or disruption of services. Developing, documenting, and implementing security policies are the primary mechanisms by which management communicates its views and requirements; these policies also serve as the basis for adopting specific procedures and technical controls.

NARA has developed information security policies and procedures that are based on NIST guidelines. For example, NARA has developed individual policy documents that address all of the families of controls listed in NIST Special Publication 800-53. To illustrate, NARA has developed information security methodologies that correspond to the controls required by NIST in the areas of access controls, configuration management, contingency planning, and security awareness training.

However, NARA’s policies and procedures were not always consistent with NIST guidance. For example, NARA has not always prescribed controls based on the system’s impact. NIST requires organizations to determine their information systems’ impact using the security objectives of confidentiality, integrity, and availability and states that this information system impact level must be determined prior to the consideration of minimum security requirements and the selection of security controls for those information systems. Instead, NARA prescribed controls based on individual security objectives without taking into consideration the predetermined impact level (based on the three security objectives) of an individual system. To illustrate, NARA’s access control policy only specifies controls for systems with moderate or high confidentiality, rather than suggesting controls according to the impact of the system, as determined by all three security objectives. Similarly, NARA’s certification and accreditation and contingency planning methodologies prescribed controls for systems with moderate or high integrity and availability, respectively, and not based on the impact level of the system. As a result, NARA’s policy may not provide the information needed to ensure that appropriate systems controls are selected that protect its information systems.

Security Plans Contained Varying Levels of Information and Did Not Always Address Required Controls

An objective of system security planning is to improve the protection of information technology resources. A system security plan provides an overview of the system’s security requirements and describes the controls that are in place—or planned—to meet those requirements. OMB Circular No. A-130 requires that agencies develop system security plans for major applications and general support systems, and that these plans address policies and procedures for providing management, operational, and technical controls. NIST Special Publication 800-53 states that the security plan should be updated to address changes to the system, its environment of operation, or problems identified during plan implementation or security control assessments. One of the controls recommended by NIST Special Publication 800-53 is the development of an inventory of an information system’s components. This inventory should, among other things, accurately reflect the current information system, be consistent with the authorized boundary of the system, and be available for review. NARA’s Security Architecture Planning Methodology also outlines security responsibilities, including responsibilities for information system owners and information owners to carry out related to system security plans. This methodology in turn mandates the use of baseline controls identified by NIST in Special Publication 800-53.

NARA prepared and documented security plans for the 10 systems and networks we reviewed. All system security plans that we reviewed, with the exception of NARANET’s wireless plan, identified management, technical, and operational controls, in accordance with NIST guidance and NARA policy.

However, NARA did not always include required controls in its system security plans. For example, 7 of the 13 system security plans reviewed did not include a system component inventory or address where that inventory could be found. In addition, NARA has not updated its badge and access system security plan since 2003, despite replacing the system in 2007. NARA had scheduled to correct this weakness by the end of 2009, but as of September 2010 it had not been corrected. Further, NARA system security plans varied in documenting security roles and responsibilities for key individuals. Some plans were missing one or more assignments for these roles. Specifically, 6 of the 13 plans did not have the required information system owner role identified, and none of the plans reviewed had the information owner role identified or assigned.

By not addressing inventory control and assigning key security responsibilities in the system security plan, NARA increases the risk that critical information may not be available to those responsible for implementing system security plans, potentially causing a misapplication of controls to the system.

Security Awareness Training and Specialized Security Training Were Not Effectively Tracked

According to FISMA, an agencywide information security program must include security awareness training for agency personnel, contractors, and other users of information systems that support the agency’s operations and assets. This training must cover (1) information security risks associated with users’ activities and (2) users’ responsibilities in complying with agency policies and procedures designed to reduce these risks. FISMA also includes requirements for training personnel with significant responsibilities for information security. In addition, OMB requires that personnel be trained before they are granted access to systems or applications. The training is intended to ensure that personnel are aware of the system or application’s rules, their responsibilities, and their expected behavior. Further, NARA policy requires that managers and users of NARA information systems be made aware of the security risks associated with their activities and of the applicable laws, executive orders, directives, policies, standards, instructions, regulations, or procedures related to the security of NARA information systems. The policy also states that NARA must ensure that personnel are adequately trained to carry out their assigned information security-related duties and responsibilities.

NARA has a security awareness training program in place and maintains records of this training in its Learning Management System. Users are required to complete a Web-based course and, after completion, acknowledge they have reviewed and understand their security responsibilities. According to NARA’s fiscal year 2009 FISMA report, the CIO reported that 100 percent of NARA’s employees had received security awareness training. NARA’s Inspector General concurred with this assessment. The CIO also reported that 50 employees had significant security responsibilities, and that all 50, had received specialized training. NARA’s Inspector General reported a higher number stating that 114 employees had significant security responsibilities, and that 83 (73 percent) received specialized training.

However, records from NARA’s training system indicated that not all users had both completed the training and acknowledged that they reviewed and understood their security responsibilities in fiscal year 2009. According to NARA’s records, as of August 20, 2009, 563 of 4,536 individuals had completed only the class portion (12 percent) and 369 individuals (8 percent) had completed only the acknowledgment portion (although in many cases had at least started the class portion). Seven hundred and forty-nine individuals (17 percent) had not completed either portion (see fig. 2).

According to NARA’s Chief Information Security Officer, limitations in the training tracking system led NARA to give credit for a user interacting with the system in some way, meaning that a user who had at least started the training course received credit for the security awareness training. In addition, records of specialized security training provided by NARA indicated that 115 individuals were required to take specialized security training; of these 115, 48 (42 percent) had no record of taking specialized training. NARA officials stated that these individuals were provided with an alternate form of training to ensure their compliance with FISMA, such as a one-on-one review or an opportunity to review briefing slides.

Without an effective method for tracking that employees and contractors fully complete security awareness training, NARA has less assurance that staff are aware of the information security risks and responsibilities associated with their activities. In addition, without ensuring that all employees with specialized security responsibilities receive adequate specialized training, NARA’s ability to implement security measures effectively could be limited.

NARA Did Not Fully Test Controls

A key element of an information security program is to test and evaluate policies, procedures, and controls to determine whether they are effective and operating as intended. This type of oversight is fundamental because it demonstrates management’s commitment to the security program, reminds employees of their roles and responsibilities, and identifies and mitigates areas of noncompliance and ineffectiveness. FISMA requires that the frequency of tests and evaluations of management, operational, and technical controls be based on risks and occur no less than annually. OMB requires that systems be authorized for processing at least every 3 years. NARA’s policy for testing is consistent with FISMA and requires that certification testing be conducted in support of system authorizations or accreditations.

NARA had conducted tests for each of the 10 systems we reviewed; however, it had not sufficiently tested controls for 2 systems. For example, the management and operational controls for 1 system were not tested at least annually. Although NARA tested technical controls and documented test results for that system, it did not test and document the results for the system’s management and operational controls. Another system had not been tested to support its accreditation since 2003. While an annual assessment was conducted in 2009 for that system, NARA’s 2007 security accreditation memorandum stated that certification testing had not been performed. As a result, NARA may have reduced assurance that controls over its information and information systems are adequately implemented and operating as intended.

Remedial Action Plans Were Not Reliably Maintained

Remedial action plans, also known as plans of action and milestones (POA&M), help agencies identify and assess security weaknesses in information systems, set priorities, and monitor progress in correcting the weaknesses. NIST guidance states that each federal civilian agency must report all incidents and internally document remedial actions and their impact. POA&Ms should be updated to show progress made on current outstanding items and to incorporate the results of the continuous monitoring process. In addition, FISMA and NARA policy require the agency CIO to report annually to the agency head on the effectiveness of the agency information security program, including progress on remedial actions.

NARA has implemented a remedial action process to assess and correct security weaknesses. The format for its system-level POA&Ms includes the types of information specified in NIST and OMB guidance, such as a description of the weakness, resources required to mitigate it, scheduled completion date, the review that identified the weakness, and the status of corrective actions (ongoing or completed).

Although NARA has developed POA&Ms to address known weaknesses, the agency does not always update these plans or complete remedial actions in a timely manner. For example, a POA&M for a system designed to receive, preserve, and provide access to electronic records is dated December 2008. None of the remedial actions described in this plan were marked as completed as of April 2010. Additionally, 8 of 10 POA&Ms that we assessed contained blank entries or “to be determined” notations for some required information. These 8 did not provide all of the information for resources needed, scheduled completion dates, milestones, or the security review that identified the weakness.

In addition, a POA&M maintained by the Office of Information Services did not include information about resources required to correct these weaknesses. This lack of information about resource requirements may inhibit the agency’s efforts to correct the security weaknesses. Outdated and incomplete POA&Ms compromise the ability of the CIO and other NARA officials to track, assess, and report accurately the status of the agency’s information security.

Security Incident Tracking Was Inconsistent

Although strong controls may not block all intrusions and misuse, agencies can reduce the risks associated with such events if they take steps to detect and respond to them before significant damage occurs. Accounting for and analyzing security problems and incidents are also effective ways for an agency to improve its understanding of threats and the potential costs of security incidents, and doing so can pinpoint vulnerabilities that need to be addressed so that they are not exploited again. FISMA requires that each federal agency implement an information security program that includes procedures for detecting, reporting, and responding to security incidents. When incidents occur, agencies are to notify the federal information security incident center—the United States Computer Emergency Readiness Team (US-CERT).

NARA has an incident response methodology and maintains an incident database with information about the categorization and analysis of incidents. However, NARA was not able to locate all of its weekly reports for incidents and did not consistently apply its criteria for incident categorization. According to the NARA incident response methodology, incidents involving the disclosures of personally identifiable information, even if the disclosure did not involve an IT system, should be categorized under “Investigation” (Category 6). While the records indicate that NARA reported these disclosures to US-CERT, NARA did not list them as Category 6.

NARA also categorized many of its computer security incidents inconsistently. Of 640 total incidents, 139 were classified as “Explained Anomaly” (Category 7). According to the NARA incident response methodology, this category is usually reserved for false positives and other explained anomalies. However, NARA classified a number of incidents in this category, even when the incident was not a false positive or could have been placed into another category. For example, NARA experienced site-redirection events—where a user was unwittingly directed to a malicious Web site while trying to access a legitimate site. This is a form of social engineering, which is categorized in the NARA incident response methodology under a separate category (Category 5). In addition, incidents where encrypted laptops were stolen were included in the “Explained Anomaly” category, though the NARA incident response methodology indicates that they should have been placed in Category 1, which indicates that unauthorized access may have occurred.

NARA policy requires that staff be assigned and trained for the incident response team. While NARA tracks information security incidents and their resolution, it has not formally tracked training held for incident response. NARA officials have stated that they are in the process of formalizing this training program. Without ensuring that incident response personnel have received appropriate training, NARA’s ability to implement security measures effectively could be limited. Further, without categorizing incidents appropriately, NARA’s ability to analyze incidents for follow-on actions could be diminished, and corrective actions for protecting agency resources may not be taken.

Contingency Plans Were Developed for Most Systems

Contingency planning is a critical component of information protection. If normal operations are interrupted, network managers must be able to detect, mitigate, and recover from service disruptions while preserving access to vital information. Therefore, a contingency plan details emergency response, backup operations, and disaster recovery for information systems. It is important that these plans be clearly documented, communicated to potentially affected staff, updated to reflect current operations, and regularly tested. Moreover, if contingency planning controls are inadequate, even relatively minor interruptions can result in lost or incorrectly processed data, which can lead to financial losses, expensive recovery efforts, and inaccurate or incomplete information.

FISMA requires each agency to develop, document, and implement plans and procedures to ensure continuity of operations for information systems that support the agency’s operations and assets. Both NIST and NARA require that contingency plans be developed and tested for information systems.

NARA developed contingency plans for 9 of the 10 systems we reviewed. Further, NARA had tested each of the contingency plans. However, a contingency plan was not developed for a system key to tracking physical records. NARA identified this weakness, but had not corrected it during the time of our review. Although all the systems in our review were tested for contingencies, NARA has less assurance that it can appropriately recover a key system in a timely manner from certain service disruptions.

Conclusions

NARA has taken important steps in implementing controls to protect the information and systems that support its mission. However, significant weaknesses in access controls and other information security controls exist that impair its ability to ensure the confidentiality, integrity, and availability of the information and systems supporting its mission. The key reason for many of the weaknesses is that NARA has not yet fully implemented elements of its information security program to ensure that effective controls are established and maintained. Effective implementation of such a program includes establishing appropriate policies and procedures, providing security awareness training, responding to incidents, and ensuring continuity of operations. Ensuring that NARA implements key information security practices and controls also requires effective management oversight and monitoring. However, until NARA implements these controls, it will have limited assurance that its information and information systems are adequately protected against unauthorized access, disclosure, modification, or loss.

Recommendations for Executive Action

To help establish an effective information security program for NARA’s information and information systems, we recommend that the Archivist of the United States take the following 11 actions: Update NARA’s system documentation and inventory to reflect accurate FIPS 199 categorizations.

Conduct physical security risk assessments of NARA’s buildings and facilities based on facility-level and federal requirements.

Revise NARA’s IT security methodologies, including those for access controls, certification and accreditation, and contingency planning, to include NIST’s minimum system control requirements.

Include inventory information and roles and responsibilities assignments in system security plans.

Improve NARA’s training process to ensure that all required personnel meet security awareness training requirements.

Implement a process that ensures all required NARA personnel with significant security responsibilities meet specialized training requirements.

Test management, operational, and technical controls for all systems at least annually.

Conduct certification testing when authorizing systems to operate.

Update remedial action plans in a timely manner and include required resources necessary for mitigating weaknesses, scheduled completion dates, milestones, and how weaknesses were identified.

Improve the incident tracking process to ensure that incidents are appropriately categorized and that personnel responsible for tracking and reporting incidents are trained.

Develop a contingency plan for the system that tracks physical records.

In a separate upcoming report with limited distribution, we plan to make 213 recommendations to enhance NARA’s access controls to address the 142 weaknesses identified during this audit.

Agency Comments and Our Evaluation

In providing written comments on a draft of this report (reprinted in app. III), the Archivist of the United States stated that he was pleased with the positive recognition of NARA’s efforts and that he generally concurred with our recommendations. NARA also provided technical comments, which we have incorporated as appropriate.

In addition, the Archivist in his comments disagreed with three of the report’s findings. First, he disagreed that NARA’s risk assessments in its systems inventory were incorrectly applied. However, our finding does not state that the risk assessments were incorrectly applied. Rather, as we discuss in the report, NARA system documentation and system inventories do not consistently reflect the FIPS 199 impact levels of its systems. These inconsistencies may reduce NARA’s assurance that adequate controls are in place to protect its information and information systems. Thus, we continue to believe our finding is appropriate.

Secondly, the Archivist disagreed that NARA policies and procedures were not always consistent with NIST guidance. As we discuss in our report, NIST states that an agency must first determine the security category of its information systems and then apply the appropriately tailored set of baseline security controls. However, NARA’s policy prescribed controls based on the individual security objectives of confidentiality, integrity, and availability instead of applying controls based on a prior determination of the system’s impact. We believe that without first identifying the impact of the system, NARA’s policy may not provide the information needed to ensure that appropriate systems controls are selected that protect its information systems. Thus, we continue to believe our finding is valid.

Lastly, the Archivist disagreed that the information owner role must be identified in each system security plan. However, NARA’s policy as discussed in the report outlines key individual roles and responsibilities, including the information owner, which should be assigned for each system. By not clearly and consistently assigning these roles, NARA increases the risk that critical information may not be available to those responsible for implementing system security plans. Thus, we continue to believe our finding is valid.

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. At that time, we will send copies of this report to interested congressional committees and to the Archivist of the United States. In addition, this report will be available at no charge on the GAO Web site at http://www.gao.gov.

If you have any questions about this report, please contact Gregory C. Wilshusen at (202) 512-6244 or Dr. Nabajyoti Barkakati at (202) 512-4499. We can also be reached by e-mail at wilshuseng@gao.gov or barkakatin@gao.gov. Contact points for our Offices of Congressional Relations and Public Affairs may be found on the last page of this report. Key contributors to this report are listed in appendix IV.

Appendix I: Objective, Scope, and Methodology

The objective of our review was to determine whether the National Archives and Records Administration (NARA) has effectively implemented appropriate information security controls to protect the confidentiality, integrity, and availability of the information and systems that support its mission.

To determine the effectiveness of security controls, we gained an understanding of the overall network control environment, identified interconnectivity and control points, and examined controls for NARA’s networks and facilities. Using our Federal Information System Controls Audit Manual which contains guidance for reviewing information system controls that affect the confidentiality, integrity, and availability of computerized information; National Security Agency guidance; National Institute of Standards and Technology (NIST) standards and guidance; and NARA’s policies, procedures, practices, and standards, we evaluated these controls by reviewing network access paths to determine if boundaries were adequately protected; reviewing the complexity and expiration of password settings to determine if password management was enforced; analyzing users’ system authorizations to determine whether they had more permission than necessary to perform their assigned functions; observing methods for providing secure data transmissions across the network to determine whether sensitive data were being encrypted; reviewing software security settings to determine if modifications of sensitive or critical system resources were monitored and logged; observing physical access controls over unclassified and classified areas to determine if computer facilities and resources were being protected from espionage, sabotage, damage, and theft; examining configuration settings and access controls for routers, network management servers, switches, and firewalls; inspecting key servers and workstations to determine if critical patches had been installed and/or were up to date; reviewing media handling policy, procedures, and equipment to determine if sensitive data were cleared from digital media before media were disposed of or reused; reviewing nondisclosure agreements at select locations to determine if they are required for personnel with access to sensitive information; and examining access roles and responsibilities to determine whether incompatible functions were segregated among different individuals.

Using the requirements identified by the Federal Information Security Management Act of 2002 (FISMA), which establishes key elements of an agencywide information security program, and associated NIST guidelines and NARA requirements, we evaluated the effectiveness of NARA’s implementation of its security program by reviewing NARA’s risk assessment process and risk assessments for 10 systems to determine whether risks and threats were documented consistent with federal guidance; analyzing NARA policies, procedures, practices, and standards to determine their effectiveness in providing guidance to personnel responsible for securing information and information systems; analyzing security plans for 10 out of 43 systems to determine if management, operational, and technical controls were in place or planned and whether security plans reflected the current environment; examining the security awareness training process for employees and contractors to determine if they received training prior to system access; examining training records for personnel with significant responsibilities to determine if they received training commensurate with those responsibilities; analyzing NARA’s procedures and results for testing and evaluating security controls to determine whether management, operational, and technical controls were sufficiently tested at least annually and based on risk; evaluating NARA’s process to correct weaknesses and determining whether remedial action plans complied with federal guidance; reviewing incident detection and handling policies, procedures, and reports to determine the effectiveness of the incident handling program; examining contingency plans for 10 systems to determine whether those plans were developed and tested; and reviewing three IT contracts to determine if security requirements were included.

We also discussed with key security representatives and management officials whether information security controls were in place, adequately designed, and operating effectively.

To establish the reliability of NARA’s computer-processed data we performed an assessment. We evaluated the materiality of the data to our audit objectives and proceeded to assess the data by various means including: reviewing related documents, interviewing knowledgeable agency officials, and reviewing internal controls. Through a combination of methods we concluded that the data were sufficiently reliable for the purposes of our work.

We conducted this performance audit from December 2009 to October 2010 in accordance with generally accepted government auditing standards. Those standards require that we plan and perform the audit to obtain sufficient, appropriate evidence to provide a reasonable basis for our findings and conclusions based on our audit objective. We believe that the evidence obtained provides a reasonable basis for our findings and conclusions based on our audit objective.

Appendix II: NARA Organizational Chart

Appendix III: Comments from the National Archives and Records Administration

Appendix IV: GAO Contacts and Staff Acknowledgments

Staff Acknowledgments

In addition to the individuals named above, Edward Alexander, Lon Chin, West Coile, Anjalique Lawrence, and Chris Warweg (Assistant Directors); Gary Austin; Angela Bell; Larry Crosland; Saar Dagani; Kirk Daubenspeck; Denise Fitzpatrick; Fatima Jahan; Mary Marshall; Sean Mays; Lee McCracken; Jason Porter; Michael Redfern; Richard Solaski; and Jayne Wilson made key contributions to this report.