Minutes of the Meeting of the Computer System Security and Privacy Advisory Board December 9-11, 1997 National Institute of Standards and Technology Gaithersburg, MD Tuesday, December 9, 1997 A quorum being present, the meeting was called to order by Chairman Willis Ware at 9:00 a.m. The Board Secretary, Ed Roback, welcomed everyone and reviewed the agenda and related handout materials that had been provided to the members. Those members in attendance were: Genevieve Burns, John Davis, Addison Fischer, John Layton, Joe Leo, Gloria Parker, Randolph Sanovic , George Trubow, Linda Vetter, Jim Wade, and Rick Weingarten. All portions of the meeting were held in open, public session. Mr. Roback informed the members that a Federal Register notice dated December 1, 1997, had been issued calling for input to the planning process for 1998 activities of the Board. Comments are due by January 30, 1998. [Reference #1] Annual INFOSEC Survey Mr. Dan Woolley, Director, Mid-Atlantic Information Security Service, Ernst and Young, LLP, presented an overview of their 5th Annual Global Information Security Survey for 1997. [Reference #2] This survey was conducted between July and August of 1997 and covered 24 countries. The total number of responses received was 4,226 of which 627 responses were from the United States. He cited several statistics of information security losses: -- the average take of the computer-based criminal is over $800K compared with only $6.1K for an old fashioned bank robber; -- the cellular phone industry looses an estimated $1.5M a day from fraud; combined with long-distance fraud, the Telecom industry is loosing between $4B and $5B annually; and -- U.S. companies have lost $5.2B from theft of proprietary information from 1993-95 with the average loss of information being $26M per incident. Mr. Woolley said that they found that security awareness is growing. Senior management thinks information security is important and in addition to having dedicated staff, the top security person typically reports to a senior official. However, many businesses do not have formal security policies and procedures, do not monitor for network incidents, do not monitor their on-line activities or have a planned incident response capability. Lack of employee awareness, tools, human resources, budget and management awareness are clear obstacles in addressing security issues. However, security is needed to allow companies to move into new areas such as electronic commerce; integrate security as part of the normal business process; and provide the ‘safety net’ businesses need to allow the freedom to operate in the unknown. Electronic Commerce Enhancement Act of 1997 Mr. Daniel Bennett, Systems Manager for Congresswoman Anna G. Eschoo [D-CA], presented an overview of the history of the Electronic Commerce Enhancement Act of 1997, H.R. 2991, dated November 9, 1997. [Reference #3] The intent of the Bill is to make it possible for citizens to do business with the government over the internet. It would enhance electronic commerce by requiring agencies to use digital signatures, which are compatible with standards for such technology used in commerce and industry, and enable persons to submit federal forms electronically. It requires that within three years of the Act’s passage, agencies must have all such forms on the internet on a website that will be government-controlled. The electronic version of each form must be substantially identical to the existing paper copy. Only forms that are submitted to an agency more than 1,000 per year and are not required to be completed in the presence of a federal official or at a particular location will be posted. It provides for studies to be conducted on the use of digital signatures twice over a 5-year period. It addresses guidelines for acceptance of certificates, accreditation and trusted third party liability. Mr. Bennett noted the Board’s observation that the Bill did not contain any language as to security of the privacy of the information that was submitted. He indicated that hearings are expected to be held in early 1998. Having just been introduced, there will be a ‘look and see’ period over the next several months and then it is expected that the legislation will be referred to the joint committee. He encouraged further comments from the Board members. Update on Computer Security Enhancement Act of 1997 Mr. Richard Russell, Staff Member, House Technology Subcommittee, updated the Board on the progress of Computer Security Enhancement Act. Currently it is in the Senate awaiting further action. He said that Senate counterparts have expressed interest in moving it along separately so as to bring more focus to this issue. Mr. Russell also reported on two recent hearings; one on the President’s Commission on Critical Infrastructure Protection (PCCIP) report and the other on the digital signature issue. The PCCIP report draws attention to the vulnerabilities of computer security and the protections that are necessary. In general, the reaction on the Hill to the Commission report was mixed. However, everyone agreed that computer security is a pressing issue that needs to be addressed. The vulnerabilities affect both private and public systems. The Commission report also recommends significant budget increases to meet the challenges of computer security protection. Mr. Russell believes that this fact may make it easier for NIST to obtain substantial increases in their funding for computer security. While the current budget did not contain any increase in funds for NIST to enhance its computer security efforts, the House Committee is going to encourage NIST to refocus and make this a priority. He also said that he believes Congress would be receptive to a NIST request for reprogramming funds for computer security. Mr. Russell said that Congressional hearings could be held to emphasis the role of computer security within the agencies and have them report on what is being done about computer security within their own agencies. He did point out, however, that they plan to first focus on reinvigorating NIST. They are working with the Government Affairs Committee and other committees to raise this issue. His observations of the hearings on digital signature were that the concerns expressed were mixed. Some took the approach of do something, while others believed doing nothing was appropriate. An opinion that was expressed was that States and countries are going their own separate ways on this issue and would not want the federal government to interfere. Mr. Russell encouraged the Board to express their ideas and thoughts on this topic and stressed the need for commonality on this issue. He reported that they do not see the Y2K issue moving well. The learning curve is fairly steep and there is little time left to fully accomplish the task. He said that while there is not enough time to fix the problem 100%, at least we are aware of the problem. Technical Advisory Committee to Develop a Federal Information Processing Standard to Develop a Federal Key Management Infrastructure Ed Roback began this briefing by stating that the current draft document was a work-in-progress produced by some of the members of the Committee after having held six meetings. He introduced Elaine Barker of NIST who serves as a government liaison from NIST to the Committee. Ms. Barker presented an overview of the draft document covering the announcement process and intended users. The document discusses a key recovery system model, supporting components, system policy, and interoperability. She indicated that this standard will most likely have a two- year initial review cycle based on the fact that this is a new technology. The Committee continues to meet and refine this draft. Ms. Barker also showed a Key Recovery Demonstration Program video to the Board. This video presented a very general overview of the 13 federal key recovery pilots effort. Other videos on each of these pilots are available and may be shown at the next meeting of the Board. Discussion of 1998 Work Plan The members discussed future action plans for consideration for the upcoming year. They included: consideration of holding 2-day meetings rather than 3-day meetings; addressing what the Board can do for federal agencies; inviting members of the CIO Council Security subcommittee to meet with the Board; enlist the assistance of OMB as the enforcer for making agencies accountable for computer security within their agencies; ask the members of the IG community what they see as threats and vulnerabilities within their agencies with the goal of improving the quality of the review process to identify agency problems. Another issue identified was the national ID card and its affects on smart cart technology and use in areas such as biometrics. Also, certification was suggested as another area on which to focus. There being no further business for the day, the meeting was recessed at 4:55 p.m. Wednesday, December 10, 1997 The meeting was reconvened at 9 a.m. President’s Commission on Critical Infrastructure Protection (PCCIP) Final Report Briefing Commission Chairman, (Ret.) General Thomas Marsh presented a briefing on the recommendations contained in its report, Critical Foundations, which was presented to the White House on October 21, 1997. [Reference #4] This report includes a national policy, an implementation strategy, and recommendations that will serve to protect infrastructures from both physical and cyber threats and assure their continued operation. The Commission’s work and report focused primarily on getting ahead of the cyber threat. A Principals Committee composed of cabinet-level government officials is charged with preparing a proposal for the President. It is expected that the President will receive the proposal early in 1998. Conclusions reached over the year and a half of this work effort included: -- protecting our infrastructures is a public-private undertaking that requires a new partnership; -- protecting our infrastructures will take time and will require long-term efforts and a new way of thinking; -- that infrastructure protection is a shared responsibility; and -- waiting for a disaster is a dangerous strategy—now is the time to act to protect our future. The recommendations fall generally into three categories: -- actions the federal government must take; -- actions the owners and operators of infrastructures must take; and -- actions that require partnership between government and industry. The recommendations focus on protection of proprietary information and ensuring anonymity when necessary; reviewing legal impediments to information sharing, such as antitrust provisions and the Freedom of Information Act; and creating information sharing mechanisms both within and between industry and government. The consensus among all the experts is that cyber threat is sure to evolve because daily we see numerous unauthorized intrusions resulting in damage to systems, whether they be publicly or privately owned. This situations will evolve on an accelerated basis because no foreign nation since the Gulf War will take us on the battlefield, but rather seek a means to do our country harm in other ways. General Marsh said that within the next five years this kind of threat will become real, and we need to take action now. Warning centers should be established and in place within the next 3-4 years, and there should be a “stand-up” now even though we may lack the tools or know when the threats and attacks will occur or how to block them effectively. General Marsh encouraged the Board to raise this subject to the agency heads stressing the need for education and awareness of this threat. He also said that NIST should give this problem a higher priority, put more of its resources behind it, and be the leader and role model for both the civil and private sector to follow. He also stated that he believed that the Director of NIST appeared willing to see that appropriate funding be made available to increase the NIST computer security efforts. PCCIP Final Report – Information and Communications R&D Needs Board member, John Davis, representing the PCCIP, presented his observations of the research and development issues identified in the report. [Reference #5] The report found that new technologies are needed to effectively deal with the current and future vulnerabilities and that research investment is inadequate and progress is too slow. The Commission looked at the entire infrastructure including the physical and well as cyber threats. Interdependent R&D studies were also reviewed. Research is needed to secure information while stored, in transit and in process to monitor and detect active threats and notify in real time. More long term research on new concepts needs to expand to a national scale via the government. Tools, techniques, methods and equipment need to be created and offered for sale by the private sector and installed to upgrade existing infrastructures. The recommendations made were: -- conduct a detailed analysis of infrastructure R&D needs and priorities prior to establishing a final National R&D program for infrastructure assurance; -- designate appropriate government departments and agencies to manage infrastructure-specific R&D efforts; -- promote the “science” of complex, interdependent systems and conduct in-depth research that addresses national infrastructure issues; -- establish a national repository of validated infrastructure-related models and data ; -- create forums that bring together researchers, infrastructure owners and operators, and government to discuss common problems, requirements, and solutions; and -- promote education, training, and certification programs to ensure proper implementation and utilization of new technologies, methods and tools. FedCIRC Update Marianne Swanson of NIST briefed the Board on the current status of the Federal Computer Incident Response Capability (FedCIRC). She thanked the Board for the resolution that they had passed at the last Board meeting in support of the continuance of this activity and need to have funding stability. She reported that they are continuing to work the funding problem with support from the Director of NIST, correspondence to the Department of Commerce, meetings with the CIO Security Council and GITS and dialogue with OMB officials. Without any additional financial commitment, the FedCIRC will have spent its allotted funds by the end of September 1998 and will have to begin shutting down late this summer. Ms. Swanson said that NIST will continue to do what it can to have this capability continue whether it be at NIST or elsewhere in the government. Y2K Observations Mr. Greg Swift, Deputy Director, Systems Technology Center, Mitretek Systems, briefed the Board on the Year 2000 problem in actual systems. [Reference #6] It is a large-scale software maintenance problem affecting code, data, external interface specifications, products and embedded systems. Because of the level of complexity of most information systems, the difficulty of evaluating Year 2000 problems escalates. He presented several examples of inverted comparison and negative interval problems that could occur. He reported that many popular software packages are not yet compliant. Vendors often have no plans to bring old versions into compliance at all forcing an upgrade, and upgrading a system can be complex if several products must coexist on it. He closed by saying that there are lots of errors to find: finding them is relatively easy, tracing the impacts of the efforts on the IT system is harder, and determining the real-world impacts of the errors is very difficult in advance. Board Discussion Period Next, the minutes of the September meeting were unanimously approved by a motion made by Genny Burns and seconded by Linda Vetter. There was discussion of a draft resolution endorsing the current efforts on IT security training and the development of a guidance document. It was agreed that this resolution would be tabled until the guideline is issued as an official document. The Board discussed further action it might take in support of the continuance of the FedCIRC activity and empowered the Chairman to do whatever possible to indicate the Board’s endorsement of this effort and support of continued funding. The Board asked to receive a copy of the FedCIRC business plan. NIST Computer Security Program Dr. Stuart Katzke, Chief of the NIST Computer Security Division, presented an overview of the work the Division is doing to meet the needs of government and industry. [Reference #7] He reviewed the missions of NIST, the Information Technology Laboratory, and the federal mandates that exist for the computer security program. Dr. Katzke described the Division’s work efforts which included security standards, the National Information Assurance Partnership (NIAP), advisory committees and technical policy support , interagency support and information exchange and direct agency assistance projects. The focus for the future will be on electronic commerce, critical infrastructure protection, testing and assurance, high-payoff guidance and interoperability as well as other areas of government/industry collaboration. The Board offered the following suggestions to Dr. Katzke: -- have more dialogue between NIST and other agencies to better understand their need for NIST support; -- consider conducting workshops for information security tools; -- follow through with the development of an incident handling document for agency use; and -- focus on the security posture of the federal agencies and the PCCIP reports aspects of the information systems protection. Following Dr. Katzke’s presentation, the Board focused on what it could do to follow the line of money identified in the Commission report to push for some of it to be earmarked for operational functions. It was suggested that they encourage NIST to take the lead to ask for the additional funds. The Board also discussed NIST’s main mission and possible ways to increase this mission to support the computer security program and agency assistance. There were no requests for public participation, and the meeting was recessed at 5:00 p.m. Thursday, December 11, 1997 The meeting was reconvened at 9:05 a.m. AES and Crypto Update Ed Roback advised the Board of the current Advanced Encryption Standard (AES) activities. A Federal Register notice has been published requesting submissions by June 15, 1998. A conference is planned for August 1998 in California where all submissions will be made public. When asked of the target date for the delivery of an AES, Mr. Roback indicated there was no fixed time but expected at least within a two to three year time frame. As for the status of the current cryptography legislation, all bills will be carried forward to the next Congressional year. He also mentioned that NIST is working with ANSI X9 on a signature standard. Board discussion on miscellaneous topics followed. Mr. Leo presented his views on how to broaden the NIST mission to include a more operational applied approach. He suggested that NIST may want to consider performing a review function of agencies to identify their computer security vulnerabilities. He also stated that security benchmarking is another area where NIST could have a significant role. Meeting with New NIST Director Ray Kammer, newly appointed Director of NIST, spoke to the Board about his vision for NIST and the role of computer security. The Board expressed their concerns for NIST role as it relates to the recommendations of the PCCIP report and asked what NIST was prepared to do. Mr. Kammer reported that the Secretary of Commerce has stated that they are willing to accept the responsibilities but noted the strong need for funding to support this effort. NIST cannot pay for this out of its funding, said Mr. Kammer, and he suggested that the possibility of joint agency funding should be considered by the CIO Council. With regard to NIST shouldering the operational responsibilities, Mr. Kammer indicated that NIST is willing to be a pioneer to establish the function but does not see them as performing this function on a long term basis. When asked where these responsibilities should be housed, he responded that each agency should take the lead for their own agency. It was pointed out that each agency does not have the leadership and expertise capabilities to carry out the responsibilities independently. Mr. Kammer stated that it was his belief that agencies could grow into this as they have done in past situations, and pointed out that typically in the other standards-making areas of NIST, NIST does not become the operational entity. On the FedCIRC topic, Mr. Kammer would like to see it fully established and will work with the CIO Council to see that policies are pushed to encourage the continuance of it. However, he pointed out that agencies will have to be willing to provide funding. He was asked if a separate entity were created, would there be any objection to portions of NIST’s programs becoming part of this new entity. Mr. Kammer responded that he would be open to discussion if such should be proposed. Mr. Kammer said that NIST has made proposals in the FY99 budget cycle to increase the funding for the computer security program. He said that the Commerce position is that they are willing and eager to be the government coordinator for the Commission objectives. He said that the Board should feel free to recommend and include budget figures in support of the Commission’s recommendations. When asked who the Board should communicate with to help this process, Mr. Kammer responded the Secretary of Commerce, the policy and budget sides of OMB and the CIO Council. He also informed the Board that NIST is an ex- officio member of the CIO Council and Dr. Shukri Wakid, Director of the NIST Information Technology Laboratory is the representative. The Chairman thanked Mr. Kammer for his time and candor with the Board and wished him good luck on his new position. Board Discussion Time It was proposed that the Board send a letter in support of the PCCIP report endorsing the ‘red team’ establishment position and increased computer security baselines for agencies. Some felt that the best effect the Board could have would be to wait to see if there are any Presidential Directives or Executive Orders issued as a result of the reports recommendations and then address specific responsibilities as they are outlined. At that time, letters could be developed that could be sent to various agencies that could contain specific points relevant to the assigned actions. The Board requested the Secretariat to continue to invite the members of the CIO Council to attend future meetings of the Board, specifically, the co-chairs of the recently established CIO Subcommittee on Security. In the area of electronic signatures, it was suggested that this Board could facilitate the bringing together of the private sector with the civilian agencies to discuss this effort. For the March agenda, it was proposed that Marjory Blumenthal of the Computer Science and Telecommunications Board of the National Research Council be invited to brief the Board on their trustworthiness report that is to be issued soon. Other topics for the agenda included a briefing on Internet 2/NGI; monitoring of the activity of the PCCIP report; legislative updates, especially on the movement of the Computer Security Enhancement Act; cryptography update, overview of status of smart card technology. A need for a public debate of privacy of federal accountable information was identified. Rick Weingarten and George Trubow will address some of these privacy issues at the March meeting. There being no futher business, the meeting was adjourned at 12:05 p.m. References #1 December 1, 1997 Federal Register notice #2 Presentation material of Mr. Daniel Woolley #3 Presentation material of Mr. Daniel Bennett #4 Presentation material of Gen. Tom Marsh #5 Presentation material of Mr. John Davis #6 Presentation material of Mr. Greg Swift #7 Presentation material of Dr. Stuart Katzke 5