Index

Critical Infrastructure Protection: Challenges to Building a
Comprehensive Strategy for Information Sharing and Coordination
(Testimony, 07/26/2000, GAO/T-AIMD-00-268).

Pursuant to a congressional request, GAO discussed the challenges of
developing effective information sharing and coordination strategies
needed to deal with computer security threats.

GAO noted that: (1) developing the information sharing and coordination
capabilities needed to effectively deal with computer threats and actual
incidents is complex and challenging but essential; (2) data on possible
threats--ranging from viruses, to hoaxes, to random threats, to news
events, and computer intrusions--must be continually collected and
analyzed from a wide spectrum of globally distributed sources; (3) once
an imminent threat is identified, appropriate warnings and response
actions must be effectively coordinated among government agencies, the
private sector, and, when appropriate, other nations; (4) it is
important that this function be carried out as effectively, efficiently,
and quickly as possible in order to ensure continuity of operations as
well as minimize disruptions; (5) at the same time, it is not possible
to build an overall, comprehensive picture of activity on the global
infrastructure; (6) networks themselves are too big, they are growing
too quickly, and they are continually being reconfigured and
reengineered; (7) as a result, it is essential that strong partnerships
be developed between a wide range of stakeholders in order to ensure
that the right data are at the right place at the right time; (8)
creating partnerships for information sharing and coordination is a
formidable task; (9) trust needs to be established among a broad range
of parties with varying interests and expectations, procedures for
gathering and sharing information need to be developed, and technical
issues need to be addressed; (10) if the federal government itself is
going to be a credible player in response coordination, it needs to have
its own systems and assets well protected; (11) this means overcoming
significant and pervasive security weaknesses at each of the major
federal agencies and instituting governmentwide controls and mechanisms
needed to provide effective oversight, guidance, and leadership; and
(12) perhaps most importantly, this activity needs to be guided by a
comprehensive strategy to ensure that it is effective, to avoid
unnecessary duplication of effort, and to maintain continuity.

--------------------------- Indexing Terms -----------------------------

 REPORTNUM:  T-AIMD-00-268
     TITLE:  Critical Infrastructure Protection: Challenges to Building
	     a Comprehensive Strategy for Information Sharing
	     and Coordination
      DATE:  07/26/2000
   SUBJECT:  Computer security
	     Computer networks
	     Information resources management
	     Interagency relations
	     Strategic planning
	     Internal controls
	     International cooperation
IDENTIFIER:  Internet
	     ILOVEYOU Computer Virus

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GAO/T-AIMD-00-268

   * For Release on Delivery
     Expected at
     10 a.m.

Wednesday,

July 26, 2000

GAO/T-AIMD-00-268

critical infrastructure protection

Challenges to Building a Comprehensive Strategy for Information Sharing and
Coordination

        Statement of Jack L. Brock, Jr.

Director, Governmentwide and Defense Information Systems

Accounting and Information Management Division

Testimony

Before the Subcommittee on Government Management, Information and
Technology, Committee on Government Reform, House of Representatives

United States General Accounting Office

GAO

Mr. Chairman and Members of the Subcommittee:

Thank you for inviting me to participate in today's hearing on the
challenges of providing a coordinated response to computer security threats.
As you know, computer security risks have increased dramatically over the
last decade as our government and our nation have become ever more reliant
on interconnected computer systems to support critical operations and
infrastructures, including telecommunications, finance, power distribution,
emergency services, law enforcement, national defense, and other government
services. These interconnected systems are part of a global information
infrastructure that is not defined by geographic boundaries or by unity of
purpose among the individual components of the infrastructure. To a large
extent, these components are developed and maintained by private companies
and, in some cases, foreign entities. This situation is challenging nations
to consider new strategies for protecting sensitive data and
information-based assets, in part through information sharing and
coordination between public and private organizations-sometimes on an
international scale.

Today, I would like to discuss the challenges to achieving effective
coordination that we have identified over the last 2 years. Such
challenges-which include establishing trust relationships between the
government and private sector, developing the mechanisms of gathering and
sharing data, strengthening technical capabilities, and providing stronger
governmentwide leadership and continuity for critical infrastructure
protection-need to be successfully addressed in order to institute effective
information sharing and coordination mechanisms among individual components
of the infrastructure.

Increasing Need for Coordinated Response

While attacks to date have not caused widespread or devastating disruptions,
the potential for more catastrophic damage is significant. Official
estimates show that over 100 countries already have or are developing
computer attack capabilities. Hostile nations or terrorists could use
cyber-based tools and techniques to disrupt military operations,
communications networks, and other information systems or networks. The
National Security Agency has determined that potential adversaries are
developing a body of knowledge about U.S. systems and about methods to
attack these systems. According to Defense officials, these methods, which
include sophisticated computer viruses and automated attack routines, allow
adversaries to launch untraceable attacks from anywhere in the world.
According to a leading security software designer, viruses in particular are
becoming more disruptive for computer users. In 1993 only about 10 percent
of known viruses were considered destructive, harming files and hard drives.
But now about 35 percent are regarded as harmful.

Information sharing and coordination among organizations are central to
producing comprehensive and practical approaches and solutions to these
threats.

   * First, having information on threats and on actual incidents
     experienced by others can help an organization better understand the
     risks it faces and determine what preventative measures should be
     implemented.
   * Second, more urgent, real-time warnings can help an organization take
     immediate steps to mitigate an imminent attack.
   * Lastly, information sharing and coordination are important after an
     attack has occurred to facilitate criminal investigations, which may
     cross jurisdictional boundaries. Such after-the-fact coordination could
     also be useful in recovering from a devastating attack, should such an
     attack ever occur.

The recent episode of the ILOVEYOU computer virus in May 2000, which
affected governments, corporations, media outlets, and other institutions
worldwide, highlighted the need for greater information sharing and
coordination. Because information sharing mechanisms were not able to
provide timely enough warnings against the impending attack, many entities
were caught off guard and forced to take their networks off-line for hours.
Getting the word out within some federal agencies themselves also proved
difficult. At the Department of Defense, for example, the lack of
teleconferencing capability slowed the response effort because Defense
components had to be called individually. The National Aeronautics and Space
Administration (NASA) had difficulty communicating warnings when e-mail
services disappeared, and while backup communication mechanisms are in
place, NASA officials told us that they are rarely tested. We also found
that the few federal components that either discovered or were alerted to
the virus early did not effectively warn others. For example, officials at
the Department of the Treasury told us that the U.S. Customs Service
received an Air Force Computer Emergency Response Team (AFCERT) advisory
early in the morning of May 4, but that Customs did not share this
information with other Treasury bureaus.

Current Information Sharing and Coordination Efforts

A variety of activities have been undertaken in response to PDD 63,
including development and review of individual agency critical
infrastructure protection plans, identification and evaluation of
information security standards and best practices, and efforts to build
communication links. In January 2000 the White House released its National
Plan for Information Systems Protection as a first major element of a more
comprehensive effort to protect the nation's information systems and
critical assets from future attacks. The plan focuses largely on federal
efforts being undertaken to protect the nation's critical cyber-based
infrastructure. Subsequent versions are to address protecting other elements
of the nation's infrastructure, including those pertaining to the physical
infrastructure and specific roles and responsibilities of state and local
governments and the private sector.

Moreover, a number of government and private sector organizations have
already been established to facilitate information sharing and coordination.
These range from groups that disseminate information on immediate threats
and vulnerabilities, to those that seek to facilitate public-private sector
information sharing on threats pertaining to individual infrastructure
sectors, and those that promote coordination on an international scale.

At the federal level, for example, the National Infrastructure Protection
Center (NIPC), located at the Federal Bureau of Investigation (FBI), is to
serve as a focal point in the federal government for gathering information
on threats as well as facilitating and coordinating the federal government's
response to incidents impacting key infrastructures. It is also charged with
issuing attack warnings to private sector and government entities as well as
alerts to increases in threat conditions. The Federal Computer Incident
Response Capability (FedCIRC) is a collaborative partnership of computer
security and law enforcement professionals established to handle computer
security incidents and to provide both proactive and reactive security
services for the federal government. In addition, the National Institute of
Standards and Technology (NIST) is working to facilitate information sharing
in the security community by building a database containing detailed
information on computer attacks and the Critical Infrastructure Assurance
Office (CIAO) is working to coordinate private sector participation in
information gathering in the area of cyber assurance. The Administration is
also undertaking efforts to facilitate information sharing with other
nations.

Examples of other organizations focusing on information sharing and
coordination include the following:

   * Carnegie Mellon University's CERT Coordination Center, which is charged
     with establishing a capability to quickly and effectively coordinate
     communication among experts in order to limit damage, respond to
     incidents, build awareness of security issues across the Internet
     community.
   * The System Administration, Networking, and Security (SANS) Institute,
     which is a cooperative research and education organization through
     which more than 96,000 system administrators, security professionals,
     and network administrators share the lessons they are learning and find
     solutions for challenges they face.
   * The National Coordinating Center for Telecommunications, which is a
     joint industry/government organization that is focusing on facilitating
     information sharing between the telecommunications industry and
     government.
   * The Financial Services Information Sharing and Analysis Center, which
     is a similar organization that exclusively serves the banking,
     securities, and insurance industries.
   * Agora, which is a forum that is composed more than 300 people from
     approximately 100 companies and 45 government agencies, including
     Microsoft, Blue Shield, the FBI, U.S. Secret Service, U.S. Customs
     Service agents, and the Royal Canadian Mounted Police as well as local
     police, county prosecutors, and computer professionals from the Pacific
     Northwest. Members voluntarily share information on common computer
     security problems, best practices to counter them, protecting
     electronic infrastructures, and educational opportunities.
   * The Forum of Incident Response and Security Teams (FIRST), which
     provides a closed forum for incident response and security teams from
     19 countries to share experiences, exchange information related to
     incidents, and promote preventative activities.
   * The International Organization on Computer Evidence, which provides an
     international forum for law enforcement agencies to exchange
     information concerning computer crime investigation and related
     forensic issues.

Challenges to Effective Coordination

At the same time, it is not possible to build an overall, comprehensive
picture of activity on the global information infrastructure. Networks
themselves are too big, they are growing too quickly, and they are
continually being reconfigured and reengineered. As a result, it is
essential that strong partnerships be developed between a wide range of
stakeholders in order to ensure that the right data are at the right place
at the right time.

Creating partnerships for information sharing and coordination is a
formidable task. Trust needs to be established among a broad range of
parties with varying interests and expectations, procedures for gathering
and sharing information need to be developed, and technical issues need to
be addressed. Moreover, if the federal government itself is going to be a
credible player in response coordination, it needs to have its own systems
and assets well protected. This means overcoming significant and pervasive
security weaknesses at each of the major federal agencies and instituting
governmentwide controls and mechanisms needed to provide effective
oversight, guidance, and leadership. Perhaps most importantly, this activity
needs to be guided by a comprehensive strategy to ensure that it is
effective, to avoid unnecessary duplication of effort, and to maintain
continuity.

I would like to discuss each of these challenges in more detail as
successfully addressing them is essential to getting the most from
information sharing mechanisms currently operating as well as establishing
new ones.

Establishing Trust Relationships

Moreover, as we testified before this Subcommittee in June, concerns have
been raised that industry could potentially face antitrust violations for
sharing information with other industry partners, subject their information
the Freedom of Information Act (FOIA) disclosures or face potential
liability concerns for information shared in good faith. Further, there is a
concern that an inadvertent release of confidential business material, such
as trade secrets or proprietary information, could damage reputations, lower
consumer confidence, hurt competitiveness, and decrease market shares of
firms.

Some of these concerns are addressed by this Subcommittee's proposed Cyber
Security Information Act of 2000 (H.R. 4246). Specifically, the bill would
protect information being provided by the private sector from disclosure by
federal entities under FOIA or disclosure to or by any third party. It would
prohibit the use of information by any federal and state organization or any
third party in any civil actions. And it would enable the President to
establish and terminate working groups composed of federal employees for the
purposes of engaging outside organizations in discussions to address and
share information about cyber security. By removing these concerns about
sharing information on critical infrastructure threats, H.R. 4246 can
facilitate private-public partnerships and help spark the dialogue needed to
identify threats and vulnerabilities and to develop response strategies.

For several reasons, the private sector may also have reservations about
sharing information with law enforcement agencies. For example, law
enforcement entities have strict rules regarding evidence in order to
preserve its integrity for prosecuting cases. Yet, complying with law
enforcement procedures can be costly because it requires training,
implementing proper auditing and control mechanisms, and following proper
procedures. Additionally, a business may not wish to report an incident if
it believes that its image might be tarnished.

For national security reasons, the government itself may be reluctant to
share classified information that could be of value to the private sector in
deterring or thwarting electronic intrusions and information attacks.
Moreover, declassifying and sanitizing such data takes time, which could
affect time-critical operations. Nevertheless, until the government provides
detailed information on specific threats and vulnerabilities, the private
sector will not be able to build a business case to justify information
sharing and will likely remain reluctant to share its own information.

Figure 1: Examples of Stakeholders in Information Sharing Efforts

Establishing Reporting Needs and Communication Mechanisms

After determining what types of information to collect and report,
guidelines and procedures need to be established to effectively collect and
disseminate data and contact others during an incident. Among other things,
this involves identifying the best mechanisms for disseminating advisories
and urgent notices, such as e-mail, fax, voice messages, pagers, or cell
phones; designating points-of-contact; identifying the specific
responsibilities of information-sharing partners; and deciding whether and
how information should be shared with outside organizations.

Working through these and other issues has already proven to be a formidable
task for some information-sharing organizations. According to the CERT
Coordination Center, for example, it has taken years for incident response
and security teams to develop comprehensive policies and procedures for
their own internal operations because there is little or no experience on
which to draw from. Moreover, the incident response team community as a
whole is lacking in policies and procedures to support operations among
teams. According to the Center, progress typically comes to a halt when
teams become overwhelmed by the number of issues that need to be addressed
before they can reach agreement on basic factors such as terminology,
definitions, and priorities.

Developing Needed Technical Capabilities

At the federal level, there is also a pressing need for better computer
network intrusion detection monitoring systems to detect unauthorized and
possible criminal activity both within and across government agencies. Under
the President's National Plan for Information Systems Protection, the
federal government is working to design and implement highly automated
security and intrusion detection capabilities for federal systems. Such
systems are to provide (1) intrusion detection monitors on key nodes of
agency systems, (2) access and activity rules for authorized users and a
scanning program to identify anomalous or suspicious activity, (3)
enterprise-wide management programs that can identify what systems are on
the network, determine what they are doing, enforce access and activity
rules, and potentially apply security upgrades, and (4) techniques to
analyze operating system code and other software to determine if malicious
code, such as logic bombs, has been installed.

As we testified in February, available tools and methods for analyzing and
correlating network traffic are still evolving and cannot yet be relied on
to serve as an effective "burglar alarm," as envisioned by the plan. While
holding promise for the future, such tools and methods raise many questions
regarding technical feasibility, cost-effectiveness, and the appropriate
extent of centralized federal oversight. Accordingly, these efforts will
merit close congressional oversight as they are implemented.

Making the Federal Government a Model

While a number of factors have contributed to weak federal information
security, such as insufficient understanding of risks, technical staff
shortages, and a lack of system and security architectures, the fundamental
underlying problem is poor security program management. Agencies have not
established the basic management framework needed to effectively protect
their systems. Based on our 1998 study of organizations with superior
security programs, such a framework involves managing information security
risks through a cycle of risk management activities that include (1)
assessing risk and determining protection needs, (2) selecting and
implementing cost-effective policies and controls to meet these needs, (3)
promoting awareness of policies and controls and of the risks that prompted
their adoption, and (4) implementing a program of routine tests and
examinations for evaluating the effectiveness of policies and related
controls. Additionally, a strong central focal point can help ensure that
the major elements of the risk management cycle are carried out and can
serve as a communications link among organizational units.

While individual agencies bear primary responsibility for the information
security associated with their own operations and assets, there are several
areas where governmentwide criteria and requirements also need to be
strengthened. Specifically, there is a need for routine, periodic
independent audits of agency security programs to provide a basis for
measuring agency performance and information for strengthened oversight.
There is also a need for more prescriptive guidance regarding the level of
protection that is appropriate for agency systems. Additionally, as
mentioned earlier, gaps in technical expertise should be addressed.

Developing a Comprehensive Strategy to Ensure Effectiveness and Continuity

The National Plan for Information Systems Protection is a move towards
developing such a framework. However, it does not address a broad range of
concerns that go beyond federal efforts to protect the nation's critical
cyber-based infrastructures. In particular, the plan does not address the
international aspects of critical infrastructure protection or the specific
roles industry and state and local governments will play.

The Administration is working toward issuing a new version of the plan this
fall that addresses these issues. However, there is no guarantee that this
version will be completed by then or that it will be implemented in a timely
manner. Additionally, a sound long-term strategy to protect U.S. critical
infrastructures depends not only on implementation of our national plan, but
on appropriately coordinating our plans with those of other nations,
establishing and maintaining a dialogue on issues of mutual importance, and
cooperating with other nations and infrastructure owners.

An important element of such a plan will be defining and clarifying the
roles and responsibilities of organizations-especially federal
entities-serving as central repositories of information or as coordination
focal points. As discussed earlier, there are numerous organizations
currently collecting, analyzing, and disseminating data or guidance on
computer security vulnerabilities and incidents, including NIST, the NIPC,
FedCIRC, the Critical Information Assurance Office, the federal CIO Council,
and various units within the Department of Defense. The varying types of
information and analysis that these organizations provide can be useful.
However, especially in emergency situations, it is important that federal
agencies and others clearly understand the roles of these organizations,
which ones they should contact if they want to report a computer-based
attack, and which ones they can rely on for information and assistance.

Clarifying organizational responsibilities can also ensure a common
understanding of how the activities of these many organizations interrelate,
who should be held accountable for their success or failure, and whether
they will effectively and efficiently support national goals. Moreover, the
need for such clear delineation of responsibilities will be even more
important as international cooperative relationships in this area mature. If
such roles and responsibilities are not clearly defined and coordinated
under a comprehensive plan, there is a risk that these efforts will be
unfocused, inefficient, and ineffective.

Nevertheless, there are formidable challenges that need to be overcome to
strengthen ongoing efforts and to work toward building a more comprehensive
and effective information-sharing and coordination infrastructure. In
particular, trust needs to be established among a broad range of
stakeholders, questions on the mechanics of information sharing and
coordination need to be resolved, roles and responsibilities need to be
clarified, and technical expertise needs to be developed. Addressing these
challenges will require concerted efforts by senior executives-both public
and private-as well as technical specialists, law enforcement and national
security officials, and providers of network services and other key
infrastructure services, among others. Moreover, it will require stronger
leadership by the federal government to develop a comprehensive strategy for
critical infrastructure protection, work through concerns and barriers to
sharing information, and institute the basic management framework needed to
make the federal government a model of critical infrastructure protection.

Mr. Chairman, this concludes my statement. I would be happy to answer any
questions you or other Members of the Subcommittee may have.

(512012)

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