Wyatt Kash | The Measure of FISMA

 

Connecting state and local government leaders

Editor's Desk'commentary: The Federal Information Security Management Act could be more effective if it included more practical measures.

AS MIGHT HAVE BEEN expected, the Office of Management of Budget's annual Federal Information Security Management Act report to Congress earlier this month drew the usual criticism despite apparent improvements in information security and privacy practices.FISMA, as most of our readers know, requires each agency to protect the government's information, operations and assets. That includes documenting and implementing procedures for detecting, reporting and responding to security incidents.The FISMA report is one of those federal exercises critics love to hate. The primary complaint: Too much energy goes into documenting compliance and too little goes to protecting information.The root of the criticism ' and the issue facing critics and proponents alike ' lies in what FISMA measures.For instance, the latest report shows that among 10,304 systems at 25 major federal agencies, 92 percent have been certified and accredited, and 95 percent have been tested for security ' up from 47 percent and 60 percent respectively on 7,957 systems five years ago. At face value, that's an impressive increase.Unfortunately, so is the quadrupling of security incidents from two years ago, to 12,986. The FISMA report takes pains to credit improved awareness and reporting practices. But the truth is, the number of actual security attacks on and breaches in agency systems is substantially higher than what's reported and growing daily.What's wrong with both sets of figures is that neither measures the ingredients of security effectiveness.That's partly because of the way FISMA is worded. But even guidelines from the National Institute of Standards and Technology lack the specificity to attack the problem.That's why it's time to reassess what FISMA should measure.One model worth considering: the audit guide used by the payment card industry. Those measures won't thwart every security problem, but they do focus on core ingredients: Maintain a firewall configuration to protect data; don't use vendor-supplied defaults for system passwords and other security parameters; protect stored data; encrypt transmission of cardholder data and sensitive information across public networks; use and regularly update antivirus software; restrict physical and logical access to cardholder data; assign a unique identifier to each person with computer access; track and monitor all access to network resources and cardholder data; and regularly test security systems and processes. That is just part of what gets measured.FISMA has the right intentions. It just needs better measures.

PCI is not the answer to FISMA

While I agree with Mr. Kash that the formal way to measure FISMA should be changed, I disagree with the notion of moving to another security model such as PCI. Just ask Hannaford Bros. Co. who recently had their data breached. They were required to subscribe to PCI and were found to be in compliance just last month. However, over 4.2 million credit and debit cards were exposed between December 2007 and March of this year.


While security is the issue, the burden of managing our information systems is the real root of the problem. What we need is an overhaul on how we think and manage our ever increasing amount of electronic data and interconnected information systems. I don't know an agency or a private organization that doesn't struggle with this very real problem.


Instead of worrying about how many systems are accredited and certified (which I contend if they were truly certified and accredited they would be secured), we should be more concerned with how our information systems are designed, implemented, and managed. Maybe we should take a hard look at the groups managing these systems to ensure that they truly have the skills and knowledge to manage the keys to all our kingdoms, our data.


Jorgen T. Lazo

Federal Reserve Board of Governors

Washington

Wyatt Kash

Rick Steele






















NEXT STORY: Florida turnpike shifts gears

X
This website uses cookies to enhance user experience and to analyze performance and traffic on our website. We also share information about your use of our site with our social media, advertising and analytics partners. Learn More / Do Not Sell My Personal Information
Accept Cookies
X
Cookie Preferences Cookie List

Do Not Sell My Personal Information

When you visit our website, we store cookies on your browser to collect information. The information collected might relate to you, your preferences or your device, and is mostly used to make the site work as you expect it to and to provide a more personalized web experience. However, you can choose not to allow certain types of cookies, which may impact your experience of the site and the services we are able to offer. Click on the different category headings to find out more and change our default settings according to your preference. You cannot opt-out of our First Party Strictly Necessary Cookies as they are deployed in order to ensure the proper functioning of our website (such as prompting the cookie banner and remembering your settings, to log into your account, to redirect you when you log out, etc.). For more information about the First and Third Party Cookies used please follow this link.

Allow All Cookies

Manage Consent Preferences

Strictly Necessary Cookies - Always Active

We do not allow you to opt-out of our certain cookies, as they are necessary to ensure the proper functioning of our website (such as prompting our cookie banner and remembering your privacy choices) and/or to monitor site performance. These cookies are not used in a way that constitutes a “sale” of your data under the CCPA. You can set your browser to block or alert you about these cookies, but some parts of the site will not work as intended if you do so. You can usually find these settings in the Options or Preferences menu of your browser. Visit www.allaboutcookies.org to learn more.

Sale of Personal Data, Targeting & Social Media Cookies

Under the California Consumer Privacy Act, you have the right to opt-out of the sale of your personal information to third parties. These cookies collect information for analytics and to personalize your experience with targeted ads. You may exercise your right to opt out of the sale of personal information by using this toggle switch. If you opt out we will not be able to offer you personalised ads and will not hand over your personal information to any third parties. Additionally, you may contact our legal department for further clarification about your rights as a California consumer by using this Exercise My Rights link

If you have enabled privacy controls on your browser (such as a plugin), we have to take that as a valid request to opt-out. Therefore we would not be able to track your activity through the web. This may affect our ability to personalize ads according to your preferences.

Targeting cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

Social media cookies are set by a range of social media services that we have added to the site to enable you to share our content with your friends and networks. They are capable of tracking your browser across other sites and building up a profile of your interests. This may impact the content and messages you see on other websites you visit. If you do not allow these cookies you may not be able to use or see these sharing tools.

If you want to opt out of all of our lead reports and lists, please submit a privacy request at our Do Not Sell page.

Save Settings
Cookie Preferences Cookie List

Cookie List

A cookie is a small piece of data (text file) that a website – when visited by a user – asks your browser to store on your device in order to remember information about you, such as your language preference or login information. Those cookies are set by us and called first-party cookies. We also use third-party cookies – which are cookies from a domain different than the domain of the website you are visiting – for our advertising and marketing efforts. More specifically, we use cookies and other tracking technologies for the following purposes:

Strictly Necessary Cookies

We do not allow you to opt-out of our certain cookies, as they are necessary to ensure the proper functioning of our website (such as prompting our cookie banner and remembering your privacy choices) and/or to monitor site performance. These cookies are not used in a way that constitutes a “sale” of your data under the CCPA. You can set your browser to block or alert you about these cookies, but some parts of the site will not work as intended if you do so. You can usually find these settings in the Options or Preferences menu of your browser. Visit www.allaboutcookies.org to learn more.

Functional Cookies

We do not allow you to opt-out of our certain cookies, as they are necessary to ensure the proper functioning of our website (such as prompting our cookie banner and remembering your privacy choices) and/or to monitor site performance. These cookies are not used in a way that constitutes a “sale” of your data under the CCPA. You can set your browser to block or alert you about these cookies, but some parts of the site will not work as intended if you do so. You can usually find these settings in the Options or Preferences menu of your browser. Visit www.allaboutcookies.org to learn more.

Performance Cookies

We do not allow you to opt-out of our certain cookies, as they are necessary to ensure the proper functioning of our website (such as prompting our cookie banner and remembering your privacy choices) and/or to monitor site performance. These cookies are not used in a way that constitutes a “sale” of your data under the CCPA. You can set your browser to block or alert you about these cookies, but some parts of the site will not work as intended if you do so. You can usually find these settings in the Options or Preferences menu of your browser. Visit www.allaboutcookies.org to learn more.

Sale of Personal Data

We also use cookies to personalize your experience on our websites, including by determining the most relevant content and advertisements to show you, and to monitor site traffic and performance, so that we may improve our websites and your experience. You may opt out of our use of such cookies (and the associated “sale” of your Personal Information) by using this toggle switch. You will still see some advertising, regardless of your selection. Because we do not track you across different devices, browsers and GEMG properties, your selection will take effect only on this browser, this device and this website.

Social Media Cookies

We also use cookies to personalize your experience on our websites, including by determining the most relevant content and advertisements to show you, and to monitor site traffic and performance, so that we may improve our websites and your experience. You may opt out of our use of such cookies (and the associated “sale” of your Personal Information) by using this toggle switch. You will still see some advertising, regardless of your selection. Because we do not track you across different devices, browsers and GEMG properties, your selection will take effect only on this browser, this device and this website.

Targeting Cookies

We also use cookies to personalize your experience on our websites, including by determining the most relevant content and advertisements to show you, and to monitor site traffic and performance, so that we may improve our websites and your experience. You may opt out of our use of such cookies (and the associated “sale” of your Personal Information) by using this toggle switch. You will still see some advertising, regardless of your selection. Because we do not track you across different devices, browsers and GEMG properties, your selection will take effect only on this browser, this device and this website.