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This file is a DRAFT chapter intended to be part of the NIST
Computer Security Handbook. The chapters were prepared by
different parties and, in some cases, have not been reviewed by
NIST. The next iteration of a chapter could be SUBSTANTIALLY
different than the current version. If you wish to provide
comments on the chapters, please email them to roback@ecf.ncsl.gov
or mail them to Ed Roback/Room B154, Bldg 225/NIST/Gaithersburg, MD
20899.
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DRAFT DRAFT DRAFT DRAFT
Chapter 6: Computer and Information Security Policy
6.1 Introduction to Computer Security Policy
Organizations rely on IT resources today to handle vast amounts of
information. Because the data can vary widely in type and in
degree of sensitivity, employees need to be able to exercise
flexibility in handling and protecting it. It would not be
practical or cost-effective to require that all data be handled in
the same manner or be subject to the same protection requirements.
Without some degree of standardization, however, inconsistencies
can develop that introduce risks.
Formal IT security policy helps establish standards for IT resource
protection by assigning program management responsibilities and
providing basic rules, guidelines, and definitions for everyone in
the organization. Policy thus helps prevent inconsistencies that
can introduce risks, and policy serves as a basis for the
enforcement of more detailed rules and procedures. Ideally, policy
will be sufficiently clear and comprehensive to be accepted and
followed throughout the organization yet flexible enough to
accommodate a wide range of data, activities, and resources.
Policy formulation is an important step toward standardization of
security activities for IT resources. IT security policy is
generally formulated from the input of many members of an
organization, including security officials, line managers, and IT
resource specialists. However, policy is ultimately approved and
issued by the organization's senior management. In environments
where employees feel inundated with policies, directives,
guidelines and procedures, an IT security policy should be
introduced in a manner that ensures that management's unqualified
support is clear. The organization's policy is management's
vehicle for emphasizing the commitment to IT security and making
clear the expectations for employee involvement and accountability.
This chapter will discuss IT security policy in terms of the
different types (program-level and issue-specific), components, and
aspects of implementation. Potential cost and interdependencies
will also be noted.
6.2 Policy Types: Program-Level and Issue-Specific
Two types of policy will typically need to be developed to meet an
organization's needs: program-level and issue-specific. Program-
level policy's main function is to establish the security program,
assign program management responsibilities, state the
organizationwide IT security goals and objectives, and provide a
basis for enforcement. Issue-specific policies also need to be
developed, in order to identify and define specific areas of
concern and to state the organization's position and expectations
in relation to them. Following are discussions on these two basic
types of policy.
6.2.1 Program-level Policy
As discussed above, program-level policy is broad in scope and far-
reaching in applicability. To make the subject more manageable, an
effective approach to a discussion of program-level IT security
policy is to break general policy into its basic components:
purpose, scope, goals, responsibilities, and enforcement.
6.2.1.1 Components of Program-level Policy
Purpose: A primary purpose of program-level policy is to establish
the IT security program. This includes defining the program
management structure, the reporting responsibilities, the roles of
individuals and groups throughout the organization, and the
organizationwide goals of the security program. (Chapter 5
provides a detailed discussion of security program management and
administration.)
Additionally, program-level policy should serve the purpose of
emphasizing to all employees the importance of IT security and
clarifying the individual employee's role and responsibilities. IT
security policy may be met with a degree of skepticism unless given
appropriate visibility and support by top management, and that
visibility and support should be clearly and energetically
reflected in the program-level policy and in its emphasis on
employee participation.
The program-level policy should thus firmly establish individual
employee accountability. Employees should be made aware via the
policy that even if they are not designated IT security program
personnel, they nonetheless have significant IT security
responsibilities.
Scope: Program-level policy should be of sufficient breadth of
scope to include all of the organization's IT resources, including
facilities, hardware, software, information, and personnel. In
some instances, it may be appropriate for a policy to name specific
assets, such as major sites, installations, and large systems. In
addition to such specified assets, it is important to include an
overview of all of the types of IT resources for which the
organization is responsible, such as workstations, Local Area
Networks (LANs), standalone microcomputers, etc.
Goals: According to the National Research Council's Computers at
Risk, published in 1991, the three security-related needs
universally most emphasized among IT resource experts and the
general computer user community are integrity, availability, and
confidentiality. These concepts are the focus of many discussions
in this handbook as well. These concepts should be the basis of
the goals established for an organization in its IT security
policy. Integrity means assuring that information is kept intact,
and not lost, damaged, or modified in an authorized manner.
Availability means assuring that information is accessible to
authorized users when needed and that, to the extent possible, IT
systems are safe from accidental or intentional disablement.
Confidentiality means assuring that information is accessible only
as authorized and that it cannot be acquired by unauthorized
personnel and/or via unauthorized means.
Goals related to these concepts should be stated in meaningful ways
to employees based on the given environment. It is important that
the organization's program-level policy reflect goals that are
applicable to the specific environment by targeting the kinds of
activities, information, and terminology that employees are
familiar with.
For instance, in an organization responsible for maintaining large
but not highly confidential databases, goals related to reduction
in errors, data loss, or data corruption might be specifically
stressed. In an organization responsible for maintaining much more
confidential data, however, goals might emphasize increased
assurance against unauthorized disclosure.
Responsibilities: As noted in the earlier discussion of Purpose,
program-level policy performs the important function of
establishing the IT security program and assigning program
management responsibilities. In addition to the security program
management responsibilities, many other responsibilities throughout
the organization should also be discussed in the policy, including
the role of line managers, applications owners, data users, and the
computer systems security group.
In some instances, the relationships among various individuals and
groups may also need to be defined in the program-level policy.
Such clarification can diminish ambiguity and confusion related to
areas of responsibility or authority. It might be desirable to
clarify, for example, who is to be responsible for approving the
security measures to be used for new systems or components being
installed: Should it be the department line manager where the item
will be installed? Or should it be a designated inter-departmental
IT security specialist? It might even be desirable to indicate
under what circumstances, if any, approval of security measures
implemented would be warranted by the head of the security program.
Overall, the program-level assignment of responsibilities should
cover those activities and personnel who will be integral to the
implementation and continuity of the IT security policy.
Enforcement: Without a formal, documented IT security policy, it
is not possible for management to proceed with the development of
enforcement standards and mechanisms. Program-level policy serves
as the basis for enforcement by describing penalties and
disciplinary actions that can result from failure to comply with
the organization's IT security requirements. Discipline
commensurate with levels and types of security infractions should
be discussed. For example, serious offenses, such as theft,
conspiracy, or intentional acts of sabotage, might be designated by
policy as punishable by firing and prosecution. Lesser
infractions, such as pirating software, might be stated as
punishable by formal written reprimand.
Consideration should also be given to the fact that nonconformance
to policy can be unintentional on the part of employees. For
example, nonconformance can often be due to a lack of knowledge or
training. It can also be the result of inadequate communication
and explanation of the policy. For these reasons, it is desirable
that, along with enforcement, program-level policy make provisions
for orientation, training, and compliance within a realistic
timeframe.
6.2.2 Issue-specific Policy
Whereas program-level policy is intended to address the broadest
aspects of IT security and the IT security program framework,
issue-specific policies need to be developed to address particular
kinds of activities and, in some environments, particular systems.
The types of subjects covered by issue-specific policies are areas
of current relevance, concern, and, sometimes, controversy upon
which the organization needs to assert a position. In this manner,
issue-specific IT security policies help to standardize activities
and reduce the potential risks posed by inadequate and/or
inappropriate treatment of the IT resources. Issue-specific
policies serve to provide guidelines for the further development of
procedures and practices within the functional elements of an
organization.
Program-level policy is usually broad enough that it does not
require much modification over time. Issue-specific policies,
however, are likely to require revision and updating from time to
time, as changes in technology and related activities take place.
This is largely because as new technologies develop, some issues
diminish in importance while new ones continually appear. A major
challenge to IT security specialists has long been the fact that
for every new technology there are also new associated problems and
issues to be addressed.
For example, the enormous increase in the use of electronic mail
(E-mail) systems in recent years has introduced many new issues in
communications security, which is one of the topics that will be
briefly discussed later in this section. Many organizations today
are developing and refining communications security policies in
order to better address such questions as who should have E-mail
access, how will privileges be assigned and monitored, for what
types of activities and information is E-mail sufficiently secure,
and what criteria should be used for the re-sending (forwarding) of
messages among users.
Another topic of recent notoriety impacting IT security policies is
the threat posed by computer viruses. New viruses and new methods
of transmitting them are making it necessary that organizations
develop policies regulating activities that were once performed
freely, such as exchanging floppy disks among users, accessing
electronic bulletinboards, and using shareware products.
As for the discussion of program-level policy, a useful approach is
to first break issue-specific policy into its basic components:
statement of an issue, statement of the organization's position,
applicability, roles and responsibilities, and points of contact.
Thereafter, some of the areas that often require issue-specific
policies will be covered.
6.2.2.1 Components of Issue-specific Policy
Statement of an Issue: In order to formulate a policy on an issue,
the issue must first be defined, with any relevant terms,
distinctions, and conditions delineated. For example, an
organization might want to develop an issue-specific policy on the
use of "foreign software." "Foreign software" might be defined to
mean any software, whether applications or data, not approved,
purchased, screened, managed, and owned by the organization.
Additionally, the applicable distinctions and conditions might then
need to be included, for instance, for software privately owned by
employees but approved for use at work and for software owned and
used by other businesses under contract to the organization.
Statement of the Organization's Position: Once the issue is stated
and related terms and conditions delineated, the organization's
position or stance on the issue will need to be clearly stated. To
continue the example of developing an issue-specific policy on the
use of foreign software, this would mean stating whether use of
foreign software as defined is strictly prohibited, whether or not
there are further guidelines for approval and use, or whether case-
by-case decisions will be rendered based on some defined criteria.
Applicability: Issue-specific policies will also need to include
statements of applicability. This means clarifying where, how,
when, to whom, and to what a particular policy applies. For
example, it could be that the hypothetical policy on foreign
software is intended to apply only to the organization's own onsite
resources and employees and is not to be applicable to contractor
organizations with offices at other locations. Additionally, the
policy's applicability to employees travelling among different
sites and/or working at home who need to transport and use disks at
multiple sites might need to be clarified.
Roles and Responsibilities: Also included in issue-specific
policies should be the assignment of roles and responsibilities.
This would mean, to continue with the above example, that if the
policy permits foreign software privately owned by employees to be
used at work with the appropriate approvals, then the approval
authority granting such permission would need to be stated.
Likewise, it would need to be clarified who would be responsible
for ensuring that only approved foreign software is used on
organizational IT resources and, perhaps, for monitoring users in
regard to foreign software.
Related to the assignment of roles and responsibilities is the
inclusion of guidelines for procedures and enforcement. The issue-
specific policy on foreign-software, for example, might include
procedural guidelines for checking disks used by employees at home
or at other locations. It might also state what the penalties
would be for using unapproved foreign software on the
organization's IT systems.
Points of Contact: For any issue-specific policy, the appropriate
individuals in the organization to contact for further information,
guidance, and enforcement should be indicated. For example, for
some issues the point of contact might be a line manager; for other
issues it might be a facility manager, technical support person, or
system administrator. For yet other issues, the point-of-contact
might be a security program representative. Using the above
example once more, employees would need to know whether the point
of contact for questions and procedural information would be
his/her immediate superior, a system administrator, or a computer
security official.
6.2.2.2 Areas Appropriate for Issue-specific Policies
Some of the areas in which management today needs to consider
issue-specific IT security policies are covered in this section.
These topics are intended to provide examples and serve as sources
for ideas and analysis. Although many of these topics are standard
to any discussion of IT security, an organization would necessarily
need to tailor its policies relating to them to meet its own unique
needs.
Physical security: The physical protection of and access to IT
resources and facilities will generally need to be addressed in one
or more specific policies. In organizations with extensive IT
systems and equipment, this may mean developing policies that
address such issues as who has access to what sites/locations; how
often risks to installations are be analyzed and by whom; what
types of physical access controls and monitoring equipment are put
in place; what responsibilities will be assigned to trained
security officials and what activities and responsibilities will be
required of all employees.
Personnel Security: Depending on the types of activities being
performed, degree of data sensitivity to be encountered, and sheer
numbers of personnel, specific security policies related to
personnel screening, requirements, hiring, training, evaluating,
and firing may need to be developed and administered. It may be
appropriate that a trained personnel security specialist initiate,
review, approve, and perform all security-related personnel
actions.
Communications Security: Communications security is a complex
technical specialty unto itself. In organizations where day-to-day
business relies on communicating routinely with remote locations,
the security of the communications transmissions and lines is
usually an issue that needs to be addressed by policy. If the data
being transmitted is highly sensitive, then this concern is
magnified, and issue-specific security policies may need to be
developed on a number of activities. Issues associated with the
use of cryptography and its related options and procedures
(discussed in Chapter 19), the use of modems and dial-in lines, and
precautions against wiretapping are just some of the potential
issues to be addressed. Additionally, as noted earlier, the
proliferation of E-mail has introduced many security- and privacy-
related issues for which organizations need to document positions
and policies.
Administrative Security: Administrative security as it applies to
IT system management and oversight activities comprises many
potential security policy issues. Included are such topics as
input/output controls, training and awareness, security
certification/accreditation, incident reporting, system
configurations and change controls, and system documentation.
Risk Management: Risk management involves assessing IT resources
in terms of potential threats and vulnerabilities and planning the
means for counteracting those identified risks. Issues that will
need to be addressed by policies include how, by whom, and when the
assessments should be performed; and what type of documentation
should result.
Contingency Planning: Related to Risk Management, Contingency
Planning means planning for the emergency actions to be taken in
the event of damage, failure, and/or other disabling events that
could occur to systems. Issues that need to be addressed by
policies include determining which systems are most critical and
therefore of highest priority in contingency planning; how the
plans will be tested, how often, and by whom; and who will be
responsible for approving the plans.
6.3 Policy Implementation
Policy implementation is a process. Policy cannot merely be
pronounced by upper management in a one-time statement or directive
with high expectations of its being readily accepted and acted
upon. Rather, just as formulating and drafting policy involves a
process, implementation similarly involves a process, which begins
with the formal issuance of policy.
6.3.1 Policy Visibility
Especially high visibility should be afforded the formal issuance
of IT security policy. This is due to a combination of factors,
including the following:
- Nearly all employees at all levels will in some way be affected;
- Major organizational resources are being addressed;
- Many new terms, procedures, and activities will be introduced.
Providing visibility through such avenues as management
presentations, panel discussions, guest speakers, question/answer
forums, and newsletters can be beneficial, as resources permit.
Including IT security as a regular topic at staff meetings at all
levels of the organization can also be a helpful tactic.
As an aspect of providing visibility for IT security policies,
information should also be included regarding the applicable higher
level directives and requirements to which the organization is
responding. Educating employees as to the requirements specified
by the Computer Security Act and related OMB circulars will help
emphasize the significance and timeliness of computer security, and
it will help provide a rational basis for the introduction of IT
security policies.
6.3.2 Policy Documentation
Once IT security policy has been approved and issued, it may be
initially publicized through memorandums, presentations, staff
meetings, or a variety of means. As soon as possible, though, it
will also need to be incorporated into formal policy documentation
as well. The process of documenting policies will usually require
updating existing documentation as well as creating new
documentation.
Existing Documentation: IT security will need to be integrated
into many existing activities and practices throughout many levels
of the organization. This integration will be facilitated by
revising any existing applicable documentation to reflect new
procedures, rules, and requirements. Included may be the
modification of various existing documents, forms, and plans at all
levels of the organization to reflect the IT policy.
For example, if IT equipment purchases and/or upgrades have been
reviewed and approved based on documented criteria such as cost,
productivity, maintainability, etc., then security considerations
may need to be introduced into that criteria. Also, if it has
previously been the documented policy to review the progress and
status of internal IT systems under development, then security-
related concerns should be introduced into that review process.
New Documentation: Additionally, the development of many new
documents, such as guidelines, standards, and procedures, may be
required. This is often true in large organizations performing
many different activities and having many levels of management. In
such environments, different functional elements may have widely
differing IT systems and needs to accommodate. It is therefore
generally more practical, to the extent possible, to allow elements
to tailor their implementations of policy to meet their unique
needs. This can be accomplished through the development of
documents containing more detailed procedures and practices to be
used for specific kinds of systems and activities within
functional elements.
For example, organizations will want to issue policies to decrease
the likelihood of data loss due to technology failures and/or
operator errors. A program-level policy might state something to
the effect that: "It is the policy of the organization to ensure
against data loss due to accidents or mishaps." In an area where
extensive writing and editing of lengthy documents is performed,
such as a word processing or technical publications unit, security
documentation might be developed on saving work in-progress much
more often than would usually be done, and/or utilizing automatic
"save" features on IT systems and software. In a different type
of functional area, however, where, for example, databases are
maintained that do not undergo significant changes very often, the
security documentation might focus on procedures for the database
administrator to use in performing periodic (daily, weekly, etc.)
backups of the system.
Appropriate visibility should be afforded the IT security policy
through all applicable documentation. The more integral security
policy is to all other aspects of daily routines, the more quickly
the associated actions and practices will become natural to doing
business. Ultimately, among the goals of policy are the
assimilation of a common body of knowledge and values and the
demonstration of appropriate corresponding behaviors. Those goals
will be expedited by making the IT security policy integral to the
organization through all avenues.
6.4 Cost Considerations
There are a number of potential costs associated with developing
and implementing IT security policies. In some environments, the
major costs may be those incurred through the numerous
administrative and management activities required for drafting,
reviewing, disseminating, and publicizing the policies. In some
organizations, though, successful policy implementation may require
additional staffing, training, and equipment. In general, how
costly IT security policy development and implementation are to an
organization will depend upon how much change needs to be
accomplished in order to ensure adequate security and a basic
standardization throughout the organization.
6.5 Interrelationships
IT security policy can be related to nearly every topic covered in
this handbook on some level. This is because all of the topics
discussed in the handbook have associated issues that organizations
may need to address via policies. The topics most directly
related, however, are: IT security program management and
administration; risk management; personnel; security training and
awareness; contingency planning; and physical and environmental
security.
6.6 Conclusion
Formulating viable IT security policies is a challenge for an
organization and requires communication and understanding of the
organizational goals and potential benefits to be derived from
policies. Through a carefully structured approach to policy
development, which includes the delegation of program management
responsibility and an understanding of both program-level and
issue-specific policy components, a coherent set of policies -
integrated into sensible practices and procedures - can be
developed
6.1, para 2: IT security policy helps to provide basic standards,
guidelines, and rules for everyone in an organization.
6.2, para 1: Program-level IT security policy establishes the
security program and assigns program management responsibilities.
6.2.1.1, para 4: Program-level policy should be sufficiently broad
in scope to include all of the organization's IT resources.
6.2.1.1, para 5: Program-level IT security policy goals should
stress the universal concepts of integrity, availability, and
confidentiality.
6.2.2, para 1: Issue-specific policies address particular
activities, concerns, and, sometimes, systems.
6.2.2, para 4: New products, developments, and trends often
require the creation of corresponding issue-specific policies.
6.2.2.2, para 1: Many activities within an organization should be
considered when developing issue-specific policies, including
physical security, personnel, communications, administrative
security, risk management, and contingency planning.
6.3.1, para 1: IT security policy should be given especially high
visibility in order to help ensure employee awareness and
understanding.
6.3.2, para 4: Many existing documents of an organization will
need to be revised to reflect IT security policies, and new
documents may also need to be developed.