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February
28, 2000
M-00-07
MEMORANDUM
FOR THE HEADS OF DEPARTMENTS AND AGENCIES
| FROM: |
Jacob
J. Lew
Director |
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| SUBJECT: |
Incorporating
and Funding Security in Information Systems Investments |
This memorandum
reminds agencies of the Office of Management and Budget's (OMB)
principles for incorporating and funding security as part of agency
information technology systems and architectures and of the decision
criteria that will be used to evaluate security for information
systems investments. The principles and decision criteria are designed
to highlight our existing policy and thereby foster improved compliance
with existing security obligations; this memorandum does not constitute
new security policy. OMB plans to use the principles as part of
the FY 2002 budget process to determine whether an agency's information
systems investments include adequate security plans.
Protecting
the information and systems that the Federal government depends
on is important as agencies increasingly rely on new technology.
Agencies are working to preserve the integrity, reliability, availability,
and confidentiality of important information while maintaining their
information systems. The most effective way to protect information
and systems is to incorporate security into the architecture of
each. This approach ensures that security supports agency business
operations, thus facilitating those operations, and that plans to
fund and manage security are built into life-cycle budgets for information
systems.
This memorandum
is written pursuant to the Information Technology Management Reform
Act (the Clinger-Cohen Act) which directs OMB to develop, as part
of the budget process, a mechanism to analyze, track, and evaluate
the risks and results of major capital investments made by an executive
agency for information systems. Additionally, the Clinger-Cohen
Act calls for OMB to issue clear and concise direction to ensure
that the information security policies, processes, and practices
of the agencies are adequate. These criteria will be incorporated
into future revisions of OMB Circular A-130 ("Management of Federal
Information Resources") and should be used in conjunction with previous
OMB guidance on sound capital planning and investment control in
OMB Memorandum 97-02, "Funding Information Systems Investments";
OMB Memorandum 97-16, "Information Technology Architectures"; and
subsequent updates.
Security programs
and controls implemented under this memorandum should be consistent
with the Computer Security Act, the Paperwork Reduction Act, the
Clinger-Cohen Act, and OMB Circular A-130. They should also be consistent
with security guidance issued by the National Institute of Standards
and Technology (NIST). Security controls for national security telecommunications
and information systems should be implemented in accordance with
appropriate national security directives.
Principles
The principles
outlined below will support more effective agency implementation
of both agency computer security and critical information infrastructure
protection programs. In terms of Federal information systems, critical
infrastructure protection starts with an effort to prioritize key
systems (e.g., those that are most critical to agency operations).
Once systems are prioritized, agencies apply OMB policies and, for
non-national security applications, NIST guidance to achieve adequate
security commensurate with the level of risk and magnitude of likely
harm.
Agencies should
develop security programs and incorporate security and privacy into
information systems with attention to the following principles:
- Effective
security is an essential element of all information systems.
- Effective
privacy protections are essential to all information systems,
especially those that contain substantial amounts of personally
identifiable information. The use of new information technologies
should sustain, and not erode, the privacy protections provided
in all statutes and policies relating to the collection, use,
and disclosure of personal information.
- The increase
in efficiency and effectiveness that flows from the use of interconnected
computers and networks has been accompanied by increased risks
and potential magnitude of loss. The protection of Federal computer
resources must be commensurate with the risk of harm resulting
from any misuse or unauthorized access to such systems and the
information flowing through them.
- Security
risks and incidents must be managed in a way that complements
and does not unnecessarily impede agency business operations.
By understanding risks and implementing an appropriate level
of cost-effective controls, agencies can reduce risk and potential
loss significantly.
- A strategy
to manage security is essential. Such a strategy should be based
on an ongoing cycle of risk management and should be developed
in coordination with and implemented by agency program officials.
It should identify significant risks, clearly establish responsibility
for reducing them, and ensure that risk management remains effective
over time.
- Agency
program officials must understand the risk to systems under
their control and determine the acceptable level of risk, ensure
that adequate security is maintained to support and assist the
programs under their control, and ensure that security controls
comport with program needs and appropriately accommodate operational
necessities. In addition, program officials should work in conjunction
with Chief Information Officers and other appropriate agency
officials so that security measures support agency information
architectures.
Policy
Security should
be built into and funded as part of the system architecture. Agencies
should make security's role explicit in information technology investments
and capital programming. These actions are entirely consistent with
and build upon the principles outlined in OMB Memorandum 97-02.
Accordingly, investments in the development of new or the continued
operation of existing information systems, both general support
systems and major applications, proposed for funding in the President's
budget must:
1. Be
tied to the agency's information architecture. Proposals
should demonstrate that the security controls for components,
applications, and systems are consistent with and an integral
part of the information technology architecture of the agency.
2. Be
well-planned, by:
a) Demonstrating
that the costs of security controls are understood and are explicitly
incorporated in the life-cycle planning of the overall system
in a manner consistent with OMB guidance for capital programming.
b) Incorporating
a security plan that discusses:
- the
rules of behavior for the system and the consequences for
violating those rules;
- personnel
and technical controls for the system;
- methods
for identifying, appropriately limiting, and controlling interconnections
with other systems and specific ways such limits will be monitored
and managed;
- procedures
for the on-going training of individuals that are permitted
access to the system;
- procedures
for the on-going monitoring of the effectiveness of security
controls;
- procedures
for reporting and sharing with appropriate agency and government
authorities indications of attempted and successful intrusions
into agency systems;
- provisions
for the continuity of support in the event of system disruption
or failure.
3. Manage
risks, by:
a) Demonstrating
specific methods used to ensure that risks and the potential for
loss are understood and continually assessed, that steps are taken
to maintain risk at an acceptable level, and that procedures are
in place to ensure that controls are implemented effectively and
remain effective over time.
b) Demonstrating
specific methods used to ensure that the security controls are
commensurate with the risk and magnitude of harm that may result
from the loss, misuse, or unauthorized access to or modification
of the system itself or the information it manages.
c) Identifying
additional security controls that are necessary to minimize
risks to and potential loss from those systems that promote
or permit public access, other externally accessible systems,
and those systems that are interconnected with systems over
which program officials have little or no control.
4. Protect
privacy and confidentiality, by:
a) Deploying
effective security controls and authentication tools consistent
with the protection of privacy, such as public-key based digital
signatures, for those systems that promote or permit public access.
b) Ensuring
that the handling of personal information is consistent with
relevant government-wide and agency policies, such as privacy
statements on the agency's web sites.
5. Account
for departures from NIST Guidance. For non-national security
applications, to ensure the use of risk-based cost-effective security
controls, describe each occasion when employing standards and
guidance that are more stringent than those promulgated by the
National Institute for Standards and Technology.
In general,
OMB will consider new or continued funding only for those system
investments that satisfy these criteria and will consider funding
information technology investments only upon demonstration that
existing agency systems meet these criteria. Agencies should begin
now to identify any existing systems that do not meet these decision
criteria. They should then work with their OMB representatives to
arrive at a reasonable process and timetable to bring such systems
into compliance. Agencies should begin with externally accessible
systems and those interconnected systems that are critical to agency
operations. OMB staff are available to work with you if you or your
staff have questions or need further assistance in meeting these
requirements.
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