Jun 29, 2015

OPM: Actions to Strengthen Cybersecurity and Protect Critical IT Systems


Please see the document below published by OPM earlier this month regarding steps they are taking to strengthen their IT systems.

June 2015
I. Introduction
The recent intrusions into U.S. Office of Personnel Management (OPM) systems that house personnel and background investigation data for Federal employees and other individuals have raised questions about the security of OPM data and the integrity of its Information Technology (IT) assets. Since Director Archuleta arrived at OPM, she has led the agency in taking significant strides to enhance cybersecurity and modernize its IT systems – strides that are in many ways forging new territory and laying groundwork for the rest of government. But recently discovered incidents have underscored the fact that there is clearly more that can and must be done. Government and non-government entities are under constant attack by evolving, advanced, and persistent threats and criminal actors. These adversaries are sophisticated, well-funded, and focused. For that reason, efforts to combat them and improve Federal IT and data security must be constantly improving as well.
The following report provides a summary of the actions OPM has taken, those that are currently underway, and those that are planned for the future in order to meet this challenge. Many of these actions are based on recommendations that have been provided by independent experts such as the agency’s Inspector General (IG), the Government Accountability Office (GAO), and other Federal partners. In the coming weeks and months, the agency will continue to consult with Congress, the IG, independent experts inside and outside of government, and others to identify further actions to strengthen cybersecurity and protect its critical IT systems.
II. Prior and Ongoing Actions to Improve IT System Security
Upon Director Archuleta’s arrival, OPM engaged in an end-to-end review of its IT systems and processes. Based on that review, the agency developed a Strategic Plan for Information Technology to guide its efforts to protect its legacy systems to the maximum extent possible as it replaced them with more modern and secure systems. This plan laid out a multi-phase strategy to bolster security through realignment of professional staff, adherence to relevant laws, policies and best practices, and investments in modern tools. As Director Archuleta stated upon publication:
[The plan] provides a framework that is rooted in the use of human resources (HR) data throughout a lifecycle (“strategy to separation”), allowing for reuse of that data in our HR systems to support agile HR policies; establishes enabling successful practices and initiatives, and enterprise and business initiatives that define OPM’s IT modernization efforts; and creates a flexible and sustainable Chief Information Officer (CIO) organization led by a strong senior executive with Federal experience in information technology, program management, and HR policy.”
One of the principal elements of the plan was information security – to ensure the agency protects the identity and privacy of citizens and employees by implementing and actively monitoring standard security controls in IT systems that effectively protect the large volume of sensitive personal data collected and stored by OPM IT systems.
Under Director Archuleta’s leadership, OPM has made good on that commitment by taking 23 concrete steps to improve information security:
Improving Security
  1. Implemented two factor Strong Authentication for all privileged users, and increased the percentage of unprivileged users with two factor Strong Authentication. Requiring the utilization of a Personal Identity Verification (PIV) card or alternative form of multi-factor authentication can significantly reduce the risk of adversaries penetrating Federal networks and systems. OPM has been a leader for the Federal government in this area.
  2. Restricted remote access for network administrators and restricted network administration functions that can be performed remotely.
  3. Reviewed all connections to ensure that only legitimate business connections have access to the Internet.
  4. Deployed new hardware and software tools, including 14 essential tools to secure the network. OPM continues to deploy additional security tools to improve its cybersecurity posture, including tools that mask and redact data.
  5. Deployed anti-malware software across the environment to protect and prevent the deployment or execution of cybercrime tools that could compromise the agency’s networks.
  6. Upgraded Security Assessment and Authorization for multiple systems.
  7. Established a 24/7 Security Operations Center, staffed by certified professionals, to monitor the network for security alerts.
  8. Implemented continuous monitoring to enhance the ability to identify and respond, in real time or near real time, to cyber threats.
  9. Installed more firewalls that allow the agency to filter network traffic.
  10. Centralized security management and accountability into the Office of the CIO and staffed it with security professionals who are fully trained and dedicated to information security on a full-time basis.
  11. Conducted a comprehensive review of IT security clauses in contracts to ensure that the appropriate oversight and protocols are in place.
  12. Developed a Risk Executive Function to ensure risk mitigation at the organizational, business process, and information system levels, including development of Risk Executive Charter and Risk Registry Template.
  13. Mandated cybersecurity awareness training for the entire workforce.
Leveraging Outside Expertise
  1. Collaborated with agency partners such as the Office of Management and Budget (OMB) and the National Institute of Standards and Technology to share, learn and standardize best practices, and to ensure information security policies are rigorous and cost-effective based on a risk assessment methodology that considers both current and potential threats.
  2. Worked with the intelligence community and other stakeholders to identify high value cyber targets within the OPM network where bulk PII data are present, and mitigate the vulnerabilities of those targets to the extent practicable.
  3. Worked with law enforcement and other agencies to shore up existing security protocols, enhance the security of its systems and detect and thwart evolving and persistent threats.
  4. Bringing in management and technology expertise by adding experts from around the Government to help manage its incident response, provide advice on further actions, and ensure that Congress and the public are kept fully up-to-date on ongoing efforts.
  5. Helping other agencies hire IT leaders to ensure they can acquire the personnel needed to combat evolving cyber threats. This includes leveraging tools and flexibilities such as direct hiring, excepted service hiring flexibilities and critical pay authority to bring IT and cyber experts from the private sector into the Federal government quickly and efficiently.
Modernizing Systems
  1. Invested in network remediation and stabilization to modernize OPM’s IT footprint. From Fiscal Year 2014 to 2015, OPM nearly tripled its investment in the IT modernization effort, from $31 million to $87 million. The President’s 2016 Budget calls for an additional $21 million to further this effort. These funds would pay for maintenance of a sustained security operations center (SOC) to provide critical oversight of OPM’s security posture and real-time 24/7 monitoring of network servers to detect and respond to malicious activity. Further, this funding includes support for stronger firewalls and storage devices for capturing security log information used for analysis in incident response.
  2. Standardized operating systems. In alignment with an IG recommendation OPM will continue standardizing operating systems and applications throughout the OPM environment, with the ultimate goal of implementing configuration baselines for all operating platforms in use by OPM. Once these baselines are in place, OPM will conduct routine compliance scans against them to identify any security vulnerabilities that may exist.
Accountability
  1. Strengthened oversight of contractors. In alignment with recommendations made by the GAO, OPM is in the process of developing, documenting, and implementing enhanced oversight procedures for ensuring that a system test is fully executed for each contractor-operated system. These procedures will expand the policy for oversight of contractor systems currently in OPM’s IT Security and Privacy Handbook.
  2. Tightened policies and practices for privileged users. Consistent with guidance from OMB, OPM is reviewing the number of privileged users, and taking steps to minimize their numbers, limit functions that they can perform, limit the duration of time they can be logged in, limit the functions that can performed remotely, and log all privileged user activity. This review – to be conducted by the CIO and the new cybersecurity advisor – will be completed and will provide recommendations to the Director by July 15.
  3. Improved Portfolio Management by hiring a dedicated Level 3 IT portfolio manager, as recommended by the IG, in December 2014 to lead its IT transformation efforts and ensure that security and performance requirements are addressed across the enterprise.
These actions have put OPM in a much stronger and more secure posture than it was, when Director Archuleta assumed her role. OPM systems currently thwart the millions of intrusion attempts that target its networks every month.
Moreover, it was because of the very cybersecurity enhancements described above that OPM was able to detect the sophisticated malicious activity on its network responsible for the recent incidents described below.
III. New Actions to Bolster Security and Modernize IT Systems
The interagency incident response team has reviewed OPM’s systems and concluded that there is no evidence that the intruder remains active on those systems. Yet simply because there is no evidence that this particular threat remains active does not mean that we can decrease our vigilance. And in fact, OPM is doing just the opposite.
As discussed above, OPM has already taken a number of aggressive steps over the past 18 months to increase its cybersecurity capabilities and modernize its critical IT systems. But there is clearly more that can and must be done to meet evolving cyber threats. With that in mind, OPM is taking the following 15 new actions. Director Archuleta has directed that these actions be carried out with all due speed, as further steps to protect the critical assets and data OPM is entrusted with are of the utmost urgency.
Improving Security
  1. Completing deployment of two factor authentication – While OPM has implemented two factor Strong Authentication (through the use of smart card log in) for all privileged users, it continues to implement this process for unprivileged users. As of the end of the second quarter of Fiscal Year 2015, nearly half of unprivileged users were using two factor authentication. Director Archuleta has directed that the agency accelerate its migration to full two factor authentication, and that this process be completed – with all users migrated to smart card log in – by August 1.
  2. Expanding continuous monitoring – OPM is working with the Department of Homeland Security (DHS) to implement the Continuous Diagnostics and Mitigation program by March 2016. OPM will aggressively work with DHS to accelerate this schedule. OPM will also mandate continuous monitoring of contractor systems where feasible.
  3. Ensuring access to contractor systems – OPM will establish requirements for future contracts, as appropriate, to ensure access to contractor systems in the event of an incident. This will ensure that OPM and law enforcement agencies can access data and conduct effective and immediate response in the case of any future cyber incidents. OPM will also consider whether any additional authorities from Congress are needed in order to enforce such access.
  4. Reviewing encryption of databases – As Director Archuleta has stated, full encryption of the databases that were accessed in the recent incidents would not have been feasible, as many of OPM’s systems would not have worked if they were encrypted. Moreover, encryption would not have kept out these particular actors. That said, encryption can be a valuable tool in the agency’s overall cybersecurity strategy, as emphasized by multiple members of Congress in recent hearings. Accordingly, Director Archuleta has directed a review of all agency databases to determine if there are any instances where encryption is possible but is not currently in place – and if any such instances are found, to proceed with encryption of the data. The Director has directed this review be completed by July 15.
Leveraging Outside Expertise
  1. Hiring a new cybersecurity advisor – Director Archuleta will hire a leading cybersecurity expert from outside of government who will report directly to her. This cybersecurity advisor will work with OPM’s CIO to manage ongoing response to the recent incidents, complete development of OPM’s plan to mitigate future incidents, and assess whether long-term changes to OPM’s IT architecture are needed to ensure that its assets are secure. OPM expects this individual to be serving the agency by August 1.
  2. Consulting with outside technology and cybersecurity experts – To ensure that the agency is leveraging private sector best practices and expertise, Director Archuleta has reached out to Chief Information Security Officers at leading private sector companies that experience their own significant cybersecurity challenges. OPM will be holding a workshop with these experts in the coming weeks to help identify further steps the agency can take to protect its systems and information.
  3. Increasing consultation with the Inspector General – As OPM has embarked on its IT modernization effort, it has received and addressed recommendations from the IG at multiple points. To ensure that this collaborative work continues, Director Archuleta will meet with the IG on a bi-weekly basis to receive regular advice and counsel.
Modernizing Systems
  1. Migrating to a new IT environment – OPM is incrementally engineering a modern network capable of significantly increased security controls. This new network infrastructure environment, known as the Shell, will improve the security of OPM infrastructure and IT systems. Once the Shell is implemented, OPM IT systems will be migrated into this new environment from the current legacy Local Area Network/Wide Area Network (LAN/WAN). This process will adhere to the OPM Systems Development Life Cycle, derived from Federal standards to manage OCIO Portfolios, Programs and Projects.
  2. Finalizing the scope of the migration process – In alignment with recommendations of the Inspector General, OPM will complete an assessment of the scope of its IT modernization process before the end of the fiscal year. As part of this – and as recommended by the IG – OPM will assess the level of effort and estimated costs of the migration process. OPM will continue to track, document, and justify any changes should those estimated costs need to change.
  3. Evaluating all contracting options – In alignment with another recommendation of the IG, as OPM considers the appropriate avenues for the Mitigation and Cleanup phases of the infrastructure improvement process, it will conduct a thorough analysis on the most reasonable and appropriate course of action, and explore all available contracting avenues to determine the best option for the health of its modernization project and for the taxpayer.
  4. Calling on Congress for additional support – In addition to the proposal put forth in the President’s Budget, OPM has conducted a review to identify areas where additional funding would help accelerate the process of improving its systems. In doing so, the agency is identifying recommended enhancements that would accelerate its overall modernization project plan. OPM will be providing further detail on these proposed enhancements to the House and Senate appropriations committees by June 26.
Accountability
  1. Senior leadership accountability – Director Archuleta will initiate monthly reviews with the CIO and new cybersecurity advisor of the agency’s IT modernization and information security efforts to ensure continued progress and accountability.
  2. Establishing regular employee and contractor training – As discussed above, OPM has already conducted cybersecurity awareness training for all of its employees. Given the recent incidents, OPM will be refreshing this training for all employees and contractors handling sensitive information on appropriate cyber hygiene and practices, to ensure that every individual is doing their part to protect the agency’s sensitive data. Going forward, this training will be required on a bi-annual basis.
  3. Documenting incident response procedures – While no two cyber incidents are exactly the same, agencies should have in place clear protocols and plans of actions prepared in advance to manage incident response. OPM will document Standard Operating Procedures for how it will work with other Federal partners in the event of any future incidents. It will share these procedures with the IG to solicit feedback and advice.
  4. Ensuring compliance with the Federal Information Security Management Act (FISMA) – As recommended by the IG, OPM will modify the performance standards of all OPM system owners to require and monitor FISMA compliance for each of the information systems under their purview.
IV. Conclusion
OPM stores more Personally Identifiable Information (PII) and other sensitive records than almost any other Federal agency. This is a tremendous trust placed in the agency by the millions of current and former Federal employees, and one that OPM must continually earn through constant vigilance.
The recent breaches of OPM data make clear that cybersecurity must remain a priority for all agencies, but especially OPM. As President Obama has said, “Both state and non-state actors are sending everything they’ve got at trying to breach these systems…And this problem is not going to go away. It is going to accelerate. And that means that we have to be as nimble, as aggressive, and as well-resourced as those who are trying to break into these systems.”
Over the past 18 months, OPM has taken aggressive steps to improve security protocols, set up continuous monitoring of its systems, establish a centralized Security Operations Center, and other measures. These steps have established a firm foundation on which OPM will continue a steadfast and unyielding effort to position the agency as a leader in Federal cybersecurity. And in fact, they led directly to uncovering the recent incidents described in this report. Without the steps, malicious actors would like continue to be actively in its systems.
The persistent and continuing attacks by malicious actors make it clear OPM must remain vigilant. That is why Director Archuleta has directed the 15 new actions described above. OPM will carry out these actions without delay. In addition, OPM is calling on Congress to take swift action to assist in this effort by providing additional resources to modernize OPM’s IT systems and ensure continued appropriate oversight of the agency and its contractors.
In a world of evolving threats, there is no such thing as “total cybersecurity.” But the actions outlined above, and continued collaboration with Federal partners, Congress, and outside experts will ensure that OPM has all the tools it needs to safeguard its systems and protect the men and women that serve the Federal government.
 
 

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