Create a SAR and RAR on the OPM hack

OPMIG report attached…………The security posture of the information systems infrastructure of an organization should be regularly monitored and assessed (including software, hardware, firmware components, governance policies, and implementation of security controls). The monitoring and assessment of the infrastructure and its components, policies, and processes should also account for changes and new procurements that are sure to follow in order to stay in step with ever-changing information system technologies. The data breach at the Office of Personnel Management (OPM) is one of the largest in US government history. It provides a series of lessons learned for other organizations in industry and the public sector. Some critical security practices, such as lack of diligence to security controls and management of changes to the information systems infrastructure were cited as contributors to the massive data breach in the OPM Office of the Inspector General’s (OIG) Final Audit Report, which can be found in open source searches. Some of the findings in the report include: weak authentication mechanisms; lack of a plan for life-cycle management of the information systems; lack of a configuration management and change management plan; lack of inventory of systems, servers, databases, and network devices; lack of mature vulnerability scanning tools; lack of valid authorizations for many systems, and lack of plans of action to remedy the findings of previous audits. The breach ultimately resulted in removal of OPM’s top leadership. The impact of the breach on the livelihoods of millions of people is ongoing and may never be fully known. There is a critical need for security programs that can assess vulnerabilities and provide mitigations.There are nine steps that will help you create your final deliverables. The deliverables for this project are as follows:Security Assessment Report (SAR): This should be an 8-10 page double-spaced Word document with citations in APA format. The page count does not include figures, diagrams, tables, or citations.Risk Assessment Report (RAR): This report should be a 5-6 page double-spaced Word document with citations in APA format. The page count does not include figures, diagrams, tables, or citations.
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U.S. OFFICE OF PERSONNEL MANAGEMENT
OFFICE OF THE INSPECTOR GENERAL
OFFICE OF AUDITS
Final Audit Report
Federal Information Security Modernization Act Audit
FY 2015
Report Number 4A-CI-00-15-011
November 10, 2015
— CAUTION -This audit report has been distributed to Federal officials who are responsible for the administration of the audited program. This audit report may
contain proprietary data which is protected by Federal law (18 U.S.C. 1905). Therefore, while this audit report is available under the Freedom of
Information Act and made available to the public on the OIG webpage (http://www.opm.gov/our-inspector-general), caution needs to be exercised
before releasing the report to the general public as it may contain proprietary information that was redacted from the publicly distributed copy.
EXECUTIVE SUMMARY
Federal Information Security Modernization Act Audit – FY 2015
Report No. 4A-CI-00-15-011
November 10, 2015
Why Did We Conduct the Audit?
What Did We Find?
Our overall objective was to evaluate
OPM’s security program and
practices, as required by the Federal
Information Security Modernization
Act (FISMA). Specifically, we
reviewed the status of OPM’s
information technology security
program in accordance with the
Department of Homeland Security’s
(DHS) FISMA Inspector General
reporting instructions.
In FY 2015 OPM was the victim of a massive data breach that involved the
theft of sensitive personal information of millions of individuals. For many
years we have reported critical weaknesses in OPM’s ability to manage its
information technology (IT) environment, and warned that the agency was at
an increased risk of a data breach. In the wake of this data breach, OPM is
finally focusing its efforts on improving its IT security posture.
Unfortunately, as indicated by the variety of findings in this audit report,
OPM continues to struggle to meet many FISMA requirements.
What Did We Audit?
The Office of the Inspector General
(OIG) has completed a performance
audit of OPM’s general FISMA
compliance efforts in the specific
areas defined in DHS’s guidance and
the corresponding reporting
instructions. Our audit was conducted
from April through September 2015
at OPM headquarters in Washington,
D.C.
During this audit we did close a long-standing recommendation related to
OPM’s information security management structure. However, this audit also
determined that there has been a regression in OPM’s management of its
system Authorization program, which we classified as a material weakness in
the FY 2014 FISMA audit report. In April 2015, the Chief Information
Officer issued a memorandum that granted an extension of the previous
Authorizations for all systems whose Authorization had already expired, and
for those scheduled to expire through September 2016. Should this
moratorium on Authorizations continue, the agency will have up to 23
systems that have not been subject to a thorough security controls assessment.
We continue to believe that OPM’s management of system Authorizations
represents a material weakness in the internal control structure of the agency’s
IT security program. The moratorium on Authorizations will result in the IT
security controls of OPM’s systems being neglected. Combined with the
inadequacy and non-compliance of OPM’s continuous monitoring program,
we are very concerned that the agency’s systems will not be protected against
another attack.
Additionally, OPM’s inability to accurately inventory its systems and network
devices drastically diminishes the effectiveness of its security controls. OPM
has implemented a large number of improved security monitoring tools, but
without a complete understanding of its network, it cannot adequately monitor
its environment and therefore the usefulness of these tools is reduced.
The following page outlines the additional issues that we identified during
this FY 2015 FISMA audit.
_______________________
Michael R. Esser
Assistant Inspector General
for Audits
i
EXECUTIVE SUMMARY
Federal Information Security Modernization Act Audit – FY 2015
Summary of FY 2015 FISMA Results
? The significant deficiency related to information security governance has been dropped due to
the reorganization of the Office of the Chief Information Officer (OCIO).
? OPM’s system development life cycle policy is not enforced for all system development
projects.
? OPM does not maintain a comprehensive inventory of servers, databases, and network
devices.
? Up to 23 major OPM information systems are operating without a valid Authorization. This
represents a material weakness in the internal control structure of OPM’s IT security program.
? OPM does not have a mature continuous monitoring program. Also, security controls for all
OPM systems are not adequately tested in accordance with OPM policy.
? The OCIO has implemented an agency-wide information system configuration management
policy; however, configuration baselines have not been created for all operating platforms.
Also, all operating platforms are not routinely scanned for compliance with configuration
baselines.
? We are unable to independently attest that OPM has a mature vulnerability scanning program.
? Multi-factor authentication is not required to access OPM systems in accordance with OMB
memorandum M-11-11.
? OPM has established an Enterprise Network Security Operations Center that is responsible for
incident detection and response.
? OPM has not fully established a Risk Executive Function.
? Many individuals with significant information security responsibility have not taken
specialized security training in accordance with OPM policy.
? Program offices are not adequately incorporating known weaknesses into Plans of Action and
Milestones (POA&M) and the majority of systems contain POA&Ms that are over 120 days
overdue.
? OPM has not configured its virtual private network servers to automatically terminate remote
sessions in accordance with agency policy.
? Not all OPM systems have reviewed their contingency plans or conducted contingency plan
tests in FY 2015.
? Several information security agreements between OPM and contractor-operated information
systems have expired.
ii
ABBREVIATIONS
Authorization
CDM
CISO
DHS
DSO
ENSOC
FIPS
FISMA
FY
IOC
ISA
ISCM
ISSO
IT
LAN
MOU/A
NIST
Security Assessment and Authorization
Continuous Diagnostic and Mitigation
Chief Information Security Officer
Department of Homeland Security
Designated Security Officer
Enterprise Network Security Operations Center
Federal Information Processing Standards
Federal Information Security Modernization Act
Fiscal year
Internal Oversight and Compliance
Interconnection Security Agreements
Information Systems Continuous Monitoring
Information System Security Officer
Information Technology
Local area network
Memorandum of Understanding/Agreement
National Institute for Standards and Technology
OCIO
OIG
OMB
OPM
POA&M
SDLC
SIEM
SP
US-CERT
VPN
Office of the Chief Information Officer
Office of the Inspector General
Office of Management and Budget
Office of Personnel Management
Plan of Action and Milestones
System Development Life Cycle
Security information and event management
Special Publication
United States Computer Emergency Readiness Team
Virtual private network
iii
TABLE OF CONTENTS
IV. MAJOR CONTRIBUTORS
TO THIS REPORT
Page
EXECUTIVE SUMMARY …………………………………………………………………………….. i
ABBREVIATIONS ………………………………………………………………………………………. iii
I.
BACKGROUND …………………………………………………………………………………………….1
II.
OBJECTIVES, SCOPE, AND METHODOLOGY …………………………………………..2
III.
AUDIT FINDINGS AND RECOMMENDATIONS………………………………………….5
A. Information Security Governance …………………………………………………………………6
B. Security Assessment and Authorization …………………………………………………………9
C. Continuous Monitoring………………………………………………………………………………12
D. Configuration Management ………………………………………………………………………..14
E. Identity and Access Management ………………………………………………………………..19
F. Incident Response and Reporting ………………………………………………………………..21
G. Risk Management ……………………………………………………………………………………..23
H. Security Training ……………………………………………………………………………………..25
I. Plan of Action & Milestones……………………………………………………………………….26
J. Remote Access Management………………………………………………………………………28
K. Contingency Planning………………………………………………………………………………..29
L. Contractor Systems ……………………………………………………………………………………31
IV.
MAJOR CONTRIBUTORS TO THIS REPORT …………………………………………..33
APPENDIX I: Status of Prior OIG Audit Recommendations
APPENDIX II: The Office of the Chief Information Officer’s October 22, 2015
response to the draft audit report, issued September 30, 2015.
APPENDIX III: FY 2015 Inspector General FISMA reporting metrics
REPORT FRAUD, WASTE, AND MISMANAGEMENT
BACKGROUND
I.I.BACKGROUND
On December 17, 2002, the President signed into law the E-Government Act (Public Law
107-347), which includes Title III, the Federal Information Security Management Act. This Act
requires (1) annual agency program reviews, (2) annual Inspector General (IG) evaluations, (3)
agency reporting to the Office of Management and Budget (OMB) the results of IG evaluations
for unclassified systems, and (4) an annual OMB report to Congress summarizing the material
received from agencies. On December 18, 2014 President Obama signed Public Law 113-283,
the Federal Information Security Modernization Act (FISMA), which reiterates the need for an
annual IG evaluation. In accordance with FISMA, we conducted an evaluation of OPM’s
security program and practices. As part of our evaluation, we reviewed OPM’s FISMA
compliance strategy and documented the status of its compliance efforts.
FISMA requirements pertain to all information systems supporting the operations and assets of
an agency, including those systems currently in place or planned. The requirements also pertain
to IT resources owned and/or operated by a contractor supporting agency systems.
FISMA reemphasizes the Chief Information Officer’s strategic, agency-wide security
responsibility. At OPM, security responsibility is assigned to the agency’s Office of the Chief
Information Officer (OCIO). FISMA also clearly places responsibility on each agency program
office to develop, implement, and maintain a security program that assesses risk and provides
adequate security for the operations and assets of programs and systems under its control.
To assist agencies and IGs in fulfilling their FISMA evaluation and reporting responsibilities, the
Department of Homeland Security (DHS) Office of Cybersecurity and Communications issued
the Fiscal Year (FY) 2015 Inspector General FISMA Reporting Instructions. This document
provides a consistent form and format for agencies to report FISMA audit results to DHS. It
identifies a series of reporting topics that relate to specific agency responsibilities outlined in
FISMA. Our audit and reporting strategies were designed in accordance with the above DHS
guidance.
1
Report No. 4A-CI-00-15-011
IVII.. OBJECTIVE,
MAJOR CONTRIBUTORS
TO THIS REPORT
SCOPE, AND METHODOLOGY
Objective
Our overall objective was to evaluate OPM’s security program and practices, as required by
FISMA. Specifically, we reviewed the status of the following areas of OPM’s information
technology (IT) security program in accordance with DHS’s FISMA IG reporting requirements:
?
?
?
?
?
?
?
?
?
?
Continuous Monitoring Management;
Configuration Management;
Identity and Access Management;
Incident Response and Reporting;
Risk Management;
Security Training;
Plan of Action & Milestones (POA&M);
Remote Access Management;
Contingency Planning; and
Contractor Systems.
In addition, we evaluated the status of OPM’s IT security governance structure and the agency’s
system Authorization process, areas that have represented a material weakness in OPM’s IT
security program in prior FISMA audits.
We also audited the security controls of four major applications/systems at OPM (see the Scope
and Methodology section below for details of these audits), and followed-up on outstanding
recommendations from prior FISMA audits (see Appendix I).
Scope and Methodology
We conducted this performance audit 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 objectives. We believe that the evidence obtained provides a reasonable basis
for our findings and conclusions based on our audit objectives. The audit covered OPM’s
FISMA compliance efforts throughout FY 2015.
We reviewed OPM’s general FISMA compliance efforts in the specific areas defined in DHS’s
guidance and the corresponding reporting instructions. We also performed information security
audits on the following major information systems:
? Multi-State Plan Program Portal (Report No. 4A-RI-00-15-013, issued May 11, 2015);
? USA Performance System (Report No. 4A-HR-00-15-018, issued July 20, 2015);
2
Report No. 4A-CI-00-15-011
? Annuitant Health Benefits Open Season System (Report No. 4A-RI-00-15-019, issued
July 29, 2015); and,
? GP Plateau Baseline 6 Learning Management System (Report No. 4A-HR-00-15-015, issued
July 31, 2015).
We considered the internal control structure for various OPM systems in planning our audit
procedures. These procedures were mainly substantive in nature, although we did gain an
understanding of management procedures and controls to the extent necessary to achieve our
audit objectives. Accordingly, we obtained an understanding of the internal controls for these
various systems through interviews and observations, as well as inspection of various documents,
including information technology and other related organizational policies and procedures. This
understanding of these systems’ internal controls was used to evaluate the degree to which the
appropriate internal controls were designed and implemented. As appropriate, we conducted
compliance tests using judgmental sampling to determine the extent to which established
controls and procedures are functioning as required.
In conducting our audit, we relied to varying degrees on computer-generated data provided by
OPM. Due to time constraints, we did not verify the reliability of the data generated by the
various information systems involved. However, we believe that the data was sufficient to
achieve the audit objectives, and nothing came to our attention during our audit to cause us to
doubt its reliability.
Since our audit would not necessarily disclose all significant matters in the internal control
structure, we do not express an opinion on the set of internal controls for these various systems
taken as a whole.
The criteria used in conducting this audit included:
? DHS Office of Cybersecurity and Communications FY 2015 Inspector General Federal
Information Security Modernization Act Reporting Instructions;
? OPM Information Technology Security and Privacy Policy Handbook;
? OPM Information Technology Security FISMA Procedures;
? OPM Security Assessment and Authorization Guide;
? OPM Plan of Action and Milestones Standard Operating Procedures;
? OMB Circular A-130, Appendix III, Security of Federal Automated Information Resources;
? OMB Memorandum M-07-16, Safeguarding Against and Responding to the Breach of
Personally Identifiable Information;
? OMB Memorandum M-11-11: Continued Implementation of Homeland Security Presidential
Directive 12;
? P.L. 107-347, Title III, Federal Information Security Management Act of 2002;
3
Report No. 4A-CI-00-15-011
? P.L. 113-283, Federal Information Security Modernization Act of 2014;
? National Institute for Standards and Technology (NIST) Special Publication (SP) 800-12, An
Introduction to Computer Security;
? NIST SP 800-18 Revision 1, Guide for Developing Security Plans for Federal Information
Systems;
? NIST SP 800-30 Revision 1, Guide for Conducting Risk Assessments;
? NIST SP 800-34 Revision 1, Contingency Planning Guide for Federal Information Systems;
? NIST SP 800-37 Revision 1, Guide for Applying the Risk Management Framework to Federal
Information Systems;
? NIST SP 800-39, Managing Information Security Risk – Organization, Mission, and
Information System View;
? NIST SP 800-47, Security Guide for Interconnecting Information Technology Systems;
? NIST SP 800-53 Revision 4, Security and Privacy Controls for Federal Information Systems
and Organizations;
? NIST SP 800-60 Volume 2, Guide for Mapping Types of Information and Information
Systems to Security Categories;
? Federal Information Processing Standards (FIPS) Publication 199, Standards for Security
Categorization of Federal Information and Information Systems;
? FIPS Publication 140-2, Security Requirements for Cryptographic Modules; and,
? Other criteria as appropriate.
The audit was performed by the OIG at OPM, as established by the Inspector General Act of
1978, as amended. Our audit was conducted from April through September 2015 in OPM’s
Washington, D.C. office.
Compliance with Laws and Regulations
In conducting the audit, we performed tests to determine whether OPM’s practices were
consistent with applicable standards. While generally compliant, with respect to the items tested,
OPM’s OCIO and other program offices were not in complete compliance with all standards, as
described in section III of this report.
4
Report No. 4A-CI-00-15-011
III. AUDIT FINDINGS AND RECOMMEDATIONS
Introduction
In FY 2015 OPM was the victim of a massive data breach that involved the theft of sensitive
personal information of millions of individuals. This was an advanced attack that may have been
impossible to prevent in even the most advanced network environment. However, for many
years we have reported critical weaknesses in OPM’s ability to manage its IT environment, and
warned that the agency was at an increased risk of a data breach. OPM continuously failed a
variety of FISMA metrics and carried material weaknesses in the annual FISMA reports. Our
recommendations appeared to garner little attention, as the same findings were repeated year
after year.
In the wake of this data breach, OPM is finally focusing its efforts on improving its IT security
posture. Unfortunately, as indicated by the variety of findings in this audit report, OPM
continues to fail to meet FISMA requirements, and we now have additional concerns with the
manner in which the agency is attempting to quickly fix problems that were decades in the
making.
OPM has determined that in order to best secure the sensitive data it maintains, it must create an
entirely new technical infrastructure and migrate all of the agency’s systems into this new
environment (referred to as the ‘Shell’). OPM faces enormous hurdles in reaching its desired
outcome – many of which we do not believe the agency is adequately prepared to address. This
infrastructure i …
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