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System Security Plan (SSP) Training

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1 System Security Plan (SSP) Training
SSP course for BP Mar 2002 System Security Plan (SSP) Training March 22, 2002 Conducted by Centers for Medicare & Medicaid Services November 4 - 7, 2002

2 SSP course for BP Mar 2002 Faculty March 22, 2002 List instructors contact information

3 Risk Assessment (RA) Methodology
Describes steps to produce IS RA Report The Information Security Risk Assessment process is presented as the following three phases: System Documentation Phase Risk Determination Phase Safeguard Determination Phase

4 System Documentation Phase 1.1 System Identification

5 System Documentation Phase 1.1 System Identification (con’t)

6 System Documentation Phase 1.1 System Identification (con’t)

7 System Documentation Phase 1.1 System Identification (con’t)
1.2 Asset Identification 1.2.1 System Environment and Special Considerations 1.2.2 System Interconnection/Information Sharing 1.3 System Security Level

8 Risk Determination Phase
Identify potential dangers to information and systems (threats). Identify the system weakness that could be exploited (vulnerabilities) associated to generate the threat/vulnerability pair. Identify existing controls to reduce the risk of the threat to exploit the vulnerability. Determine the likelihood of occurrence for a threat exploiting a related vulnerability given the existing controls. Determine the severity of impact on the system by an exploited vulnerability. Determine the risk level for a threat/vulnerability pair given the existing controls. This six step process for Risk Determination is conducted for each identified threat/vulnerability pair.

9 Risk Determination Phase (con’t) Risk Determination Table

10 Risk Determination Phase (con’t) Likelihood of Occurrence Levels

11 Risk Determination Phase (con’t) Impact Severity Levels

12 Risk Determination Phase (con’t) Risk Levels Table

13 Safeguard Determination Phase (4-steps)
Identify the controls/safeguards to reduce the risk level of an identified threat/vulnerability pair, if the risk level is moderate or high. Determine the residual likelihood of occurrence of the threat if the recommended safeguard is implemented. Determine the residual impact severity of the exploited vulnerability once the recommended safeguard is implemented. Determine the residual risk level for the system.

14 Safeguard Determination Phase Safeguard Determination Phase Table
Use Table 5 to summarize the analysis performed during the Safeguard Determination Phase. Use the item numbers created for Table 1 as reference in Table 5 to correlate the analysis summarized in both tables to the same threat/vulnerability pair and associated risk level.

15 Risk Assessment Process Flow

16 RA Methodology Questions ?

17 Course Objectives Understand SSP methodology Version 3.0 (DRAFT)
Certification & Documentation Requirements for SSPs SSPs within the Information Systems Security Program

18 Legal Requirements Computer Security Act of 1987
OMB A-130, Appendix III Government Information Systems Reform Act (GISRA) of 2000 Contractual

19 CMS Requirements CMS SSP Methodology Version 3.0 (DRAFT)
CMS Risk Assessment (RA) Methodology Version 1.1

20 CMS SSP Architecture 3-Tier Architecture CMS Systems Master
General Support System (GSS) Major Application (MA) SSP Methodology Section 1.2

21 General Support Systems
Defined elements of the infrastructure that provide support for a variety of users and/or applications under the same direct management control Normally includes hardware, software, information, data, applications, communication, facilities, and people Users may be from the same or different organizations Physical platform and infrastructure with environmental software SSP Methodology Section 1.4.1

22 Major Applications Systems, usually software applications, that support clearly defined business function for which there are readily identifiable security considerations and needs Application code Examples include: MCS, FISS, CWF SSP Methodology Section 1.4.2

23 BP SSP Documentation Tab A: Certification Form
Tab B: Accreditation Form Tab C: System Security Plan with Appendices & Attachments Tab D: Summaries and References SSP Methodology Section 4.3

24 BP SSP Formal Submission
SSP course for BP Mar 2002 BP SSP Formal Submission March 22, 2002 Original Certification Form with all signatures must be forwarded to: [address] SSP with a copy of the Certification Form must be filed in your Security Profile. SSP Methodology Section 4.3

25 Reviewing and Updating an SSP
Security may degrade over time as technology changes Changes occur to authorizing legislation or requirements People and procedures change SSP Methodology Section 4.5

26 Certification Acceptance of the security risk by the system owner
Requirement for all CMS systems Based on technical evaluation of a system to see how well it meets security requirements System Owners/Manager, ISSO/SSO, and System Maintainer/Manager must sign the certification form SSP Methodology Section 4.6

27 Re-Certification Major system modification Change in security profile
Serious security violation occurs Changes to threat environment Every year Expiration of Certification SSP Methodology Section 4.6

28 Accreditation CMS Internal Systems - formal accreditation by CIO or Sr. Systems Security Advisor (SSA) Must authorize in writing the use of each system based on the SSP documentation, certification and the level of risk Accepts the risk of the system as it impacts the rest of the agency as certified by the system owner SSP Methodology Section 4.7

29 BP SSP Development Hints
The SSP is not: a future planning document an opportunity to educate the reader on security terminology, controls, best practices, etc. a document to restate the CMS views on SSP methodology The SSP is: a document that describes the current operation states what is and what is not in place, with any rational or compensating measures for what is not in place Does not need to be developed from scratch

30 SSP Development Hints Refer to/use existing system documentation
Must contain high-level summary of technical information about the system, its security requirements, and the controls implemented to provide protection against its vulnerabilities Where possible provide references to policy/procedures, responsible component, and how it can be reviewed Must be dated to allow ease of tracking modifications and approvals Use a 3-ring binder for certified SSP Maintain a history of all documentation and sign-offs

31 Questions ?

32 System Security Plan Sections
An Executive Summary is OPTIONAL. If included provide a summary of each of the first four sections of the SSP Section 1: System Identification Section 2: Management Controls Section 3: Operational Controls Section 4: Technical Controls

33 Section 1: System Identification
1.1 System Name/Title 1.2 Responsible Organization 1.3 Information Contact(s) 1.4 Assignment of Security Responsibility 1.5 System Operational Status 1.6 General Description / Purpose

34 1.1 System Name/Title Official name and title of the system, including acronym (example:) Fiscal Intermediary Standard System (FISS) SOR # Financial Management Investment Board(FMIB) N/A Web Support Team (WST) # N/A

35 1.2 Responsible Organization
Name of Organization, address, city, state, zip, contract number, contractor name (if applicable)

36 1.3 Information Contact(s)
Title, organization, address, city, state, zip, address, and phone number for: SSP Author System Owner/Manager System Maintainer/Manager Business Owner/Manager

37 1.4 Assignment of Security Responsibility
Title, organization, address, city, state, zip, address, and phone number for: Individual(s) responsible for security from BP Component Information System Security Officer/System Security Officer (ISSO/SSO) Emergency contact information (name and phone number of different person for backup) NOTE - This section must contain 4 different individuals

38 1.5 System Operational Status
New Operational Undergoing a major modification

39 1.6 General Description / Purpose
New “check one only” block for CMS On-site systems, CMS off-site system or External Business Partners (Medicare Contractors) Brief description (1-3 paragraphs) on the purpose of the system and the organizational processes supported (include major inputs/outputs, users and major business functions performed) If GSS, include all applications supported, including functions and information processed

40 1.6.1 System Environment and Special Considerations
SSP course for BP Mar 2002 System Environment and Special Considerations March 22, 2002 Brief (1-3 paragraphs) general description of the technical system describing the flow of data and processes through the infrastructure covered by the SSP. Describe environmental factors that raise special security concerns Document the physical location of the system Provide a network diagram or schematic to help identify, define, and clarify the system boundaries

41 1.6.2 System Interconnection / Information Sharing
Describe any system interconnections and/or information sharing(inputs and outputs) outside the scope of this plan Include information on the authorization for connection to other systems or the sharing of information Written management authorization must be obtained prior to connection Document any written management authorizations (MOA/MOU or Data Exchange Agreement)

42 1.6.2 System Interconnection / Information Sharing (cont’d)
For GSSs describe various components and sub-networks connections and /or interconnections to LAN or WAN For MAs provide description of the major application and sub-applications along with other software interdependencies

43 1.6.3 Applicable Laws or Regulations
List the laws and regulations not already listed in the CMS Master Plan Any laws or regulations that establish system specific requirements for confidentiality, integrity, availability, audit ability, and accountability of information in the system

44 1.6.4 General Description of Information Security Level
Appendix B, SSP Methodology Information Security Levels Table Information Security Levels by Information Categories Information Owner (CMS) must define the Information Security Level Claims processing systems have a Information Security Level of …

45 Section 1 Questions ?

46 2.0 Management Controls Management controls focus on the management of the computer security system and the management of risk for a system 2.1 Risk Assessment and Risk Management 2.2 Review of Security Controls 2.3 Rules of Behavior 2.4 Planning for Security in the Life Cycle

47 2.1 Risk Assessment and Risk Management
Attach the risk assessment to the SSP and provide a summary in this section including: Value of the system or application (ie. assets) ?? Threats Vulnerabilities Effectiveness of current or proposed safeguards Describe the methods used to assess the nature and level of risk to the GSS or MA Identify the risk assessment methodology used Complete chart in Section 2.1 of SSP

48 Sample RA Charts for 2.1

49 2.2 Review of Security Controls
Summarize any/all security evaluation conducted within the last 12 months on the system (e.g.SAS-70, GAO, IG, Internal Revenue Service, Self Assessments, CAST,audits) for each review Who performed the review When the review was performed The findings and actions taken as a result of the review Where the final report is located and who to contact for review of the final report

50 2.3 Rules of Behavior Provide summary of ROB, reference policy and how it can be reviewed Describe and document the system specific rules of behavior or “code of conduct” of users of the GSS or MA Must include the consequences of non-compliance Must clearly state the exact behavior expected of each person Include appropriate limits on interconnections to other systems Cover such matters as work at home, dial-in access, connection to the Internet, the assignment and limitation of system privileges

51 2.4 Planning for Security in the Life Cycle
Summarize how security is handled by your corporation/business entity for each phase of the life cycle, reference policy and where it can be found Phase 1: Pre-Development Phase 2: Development Phase 3: Post-Development

52 Section 2 Questions ?

53 3.0 Operational Controls Operational controls are the day-to-day procedures and mechanisms 3.1 Personnel Security 3.2 Physical and Environmental Protection 3.3 Production, I/O Controls 3.4 Incident Response Capability 3.5 Contingency Planning 3.6 Hardware, Operating Systems and System Software Maintenance Controls

54 3.0 Operational Controls - con’t
3.7 Data Integrity/Validation Controls 3.8 Documentation 3.9 Security Awareness and Training

55 3.1 Personnel Security Provide a detailed summary of personnel security requirements of your corporation/business entity, reference policy/procedures, the responsible component, and how it can be reviewed IT related positions require evaluation and sensitivity level designations and screening Mechanisms in place for holding users accountable for their actions (individual accountability) User access restrictions (least privilege) Are critical functions divided among different individuals (separation of duties)

56 3.2 Physical & Environmental Protection
Provide a detailed summary of physical and environmental protections, reference policy/procedures, the responsible component, and how it can be reviewed Describe and document the physical security and environmental controls List attributes of the physical protection afforded the area where processing of the MA system takes place Access Controls Fire Safety Factors Water sensors Plumbing Raised floor access Emergency exits

57 3.3 Production, I/O Controls
Summarize hardcopy and media controls in place, reference policy/procedures, the responsible component, and how it can be reviewed Handling, processing, storage, and disposal of media System unique production rules, if any Describe Help-Desk support, if any is provided

58 3.4 Incident Response Applies to GSS system security plans only, for MAs refer to the GSS Summarize the following information, reference policy and how it can be reviewed Detail the preventative measures in place (automated intrusion detection tools, automated audit logs, penetration testing) Describe the procedures for recognizing, handling, and reporting incidents Document who responds to alerts/advisories Describe and document the formal incident response capability and the capability to provide users with help when an incident occurs

59 3.5 Contingency Planning Provide a detailed summary of the contingency plan, reference policy and how it can be reviewed Discuss the arrangement and planned safeguards to ensure the alternate processing site will provide an adequate level of security Describe any documented backup procedures Describe coverage of backup procedures and physical location of stored backups Describe the generations of backups kept

60 3.6 Hardware, Operating System, and System Software Maintenance Controls
Summarize security controls used to monitor the installation and updates to hardware, operating system software, and other system software to ensure that the hardware and software functions as expected and that a historical record is maintained of system changes 3.6.1 Configuration Management (GSS) 3.6.2 Software Management (GSS) 3.6.3 Application Software Management Controls (MA)

61 3.6.1 Configuration Management
Applies to GSS system security plans only, for MAs refer to the GSS Summarize Configuration Management Procedures, reference policy and how it can be reviewed Testing and/or approving system components prior to production Impact analyses to determine the effect of proposed changes Change identification, approval, and documentation procedures

62 3.6.2 Software Management (Environmental Software)
Applies to GSS system security plans only, for MAs refer to the GSS Summarize software management, reference policy and how it can be reviwed Coordinate and control updates to environment software Monitor installation and updates Version Control Describe and document the policies for handling copyrighted software or shareware

63 3.6.3 Application Software Management Controls
Applies to MA security plans only Summarize Application Software Management Controls, reference policy and how it can be reviewed Describe the application software controls Version control Describe the security controls used to monitor the installation and updates of the application software Describe: (or summarize and reference procedures) If the application software is developed in-house or under contract Who owns the software How emergency fixes are handled If test data is “live” data or made-up

64 3.7 Data Integrity/Validation Controls
Summarize controls in place to prevent/detect destruction or unauthorized data modification, reference policy and how it can be reviewed Virus detection and elimination software procedures Reconciliation routines used by the system Integrity verification programs used by the application to look for evidence of data tampering, errors, and omissions System performance monitoring Message authentication

65 3.8 Documentation Describe the set of formal materials which support the operation of the GSS or MA, its components, operations, and use List the existing documentation maintained, including the title, date, and office responsible for maintaining the documentation

66 3.8 Documentation (con’t)
Hardware and software descriptions Standard operating procedures Application requirements Application program documentation and specs Security policies, standards, procedures, and approvals Emergency procedures MOU/MOAs User manuals Backup procedures

67 3.9 Security Awareness and Training
List the types and frequency of system-specific security training established, how the training is conducted, attendance is documented and how the system owner ensures that it is conducted prior to allowing access

68 Section 3 Questions ?

69 4.0 Technical Controls Technical and logical in place controls to authorize or restrict users and information. For MAs, describe additional enhancements or modifications of the controls beyond the GSS 4.1 Identification and Authentication 4.2 Authorization & Access Controls 4.3 Remote Users & Dial Up Controls Wide Area Network (WAN) Controls 4.5 Public Access Controls 4.6 Test Scripts/Results 4.7 Audit Trails

70 4.1 Identification & Authentication Controls
Provide a detailed summary of the Identification and Authentication controls in place, reference policy and how it can be reviewed Unique identification, e.g., UserId Unique authentication, e.g. password Maintenance of UserId and password Length of password and frequency of password changes For GSS state name of software used to control all aspects of UserID and password If used, describe biometrics or token controls

71 4.2 Authorization & Access Controls
SSP course for BP Mar 2002 4.2 Authorization & Access Controls March 22, 2002 Provide a detailed summary of procedures, hardware, and/or software used to control access to resources, reference policy and how it can be reviewed Role based access Separation of duties Usage of Access Control Lists (ACL’s) Security software and restricting access How access is restricted between systems Controls for detecting unauthorized access Inactive user activity and automated disconnection System access outside normal working hours

72 4.2 Authorization & Access Controls - con’d
How the access control mechanism supports individual accountability and audit trails State the number of invalid access attempts that may occur and the actions taken when that limit is exceeded If cryptography is used, provide a detailed summary of methodology and key management procedures Provide sample system-specific warning banner

73 4.3 Remote Users & Dial-up Controls
Provide a detailed summary of remote users and dial-up controls, reference policy and how it can be reviewed Describe the type of remote access (dial, Internet) permitted Functions that may or may not be authorized for remote use, i.e., differences from internal access permissions

74 4.4 Wide Area Networks (WAN) Controls
Provide a detailed summary of the wide area network controls Protection against unauthorized system penetration, Internet threats & vulnerabilities Types of network connections, e.g., Internet Describe additional hardware or technical controls to provide protection e.g., firewalls, proxy servers Network Diagram can be included

75 4. 5 Public Access Controls
Provide detail summary when or if public access is authorized, reference policy/procedures, the responsible component and how it can be reviewed Access controls used to secure the system Controls to prevent public users, if access is authorized, from modifying information on the system Legal considerations to allowing access to the information Describe rationale for the use or non-use of warning banners and provide an example of the banners used for this system If no public access state “system does not allow public access”

76 4.6 Test Scripts/Results Summarize the findings of all tests/results
Describe the test scripts and results that were used to test the effectiveness of the security controls Include title, date, and office responsible for maintaining the test scripts/results

77 4.7 Audit Trails Provide a detailed summary of existing audit trails
Document the auditing mechanisms Describe what is recorded, who reviews, how often are they reviewed and what procedures are employed for corrective actions as a result of a finding Describe when audit trails are employed, e.g., on a given cycle, continuously, when an incident occurs, etc. Describe audit trail archive procedures including how long they are kept, where stored, and what media type

78 5.0 Appendices & Attachments
Appendix A – Equipment List (Primarily for GSS) Appendix B – Software List Attachments Risk Assessment (Required)

79 Section 4 & 5 Questions ?

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