United States         Office of Information
         Environmental Protection    Resources Management
         Agency            Washington DC 20406   December 1989
&EPA       EPA INFORMATION
             SECURITY MANUAL FOR
             PERSONAL COMPUTERS

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Information Security Manual for PCs	                   12/15/89

                                 PREFACE

 Recently, information security has achieved  a new and unfamPiar  prominence.
 Information security issues have  appeared on the  covers of both  Time" and
 "Business  Week"  magazines.   Congress  has emphasized the  importance  of
 information security through its passage of the Computer Security Act of 1987.

 What this newfound prominence seems to highlight is that we are now truly in the
Age of Information.  The  explosion in personal computing is the latest step in
 creating this information society.   As we have become more dependent on our
 information resources, so have we also become more concerned about what might
 happen if those resources were lost or misused.

At trie EPA, the Agency information security  policy is contained in a formal  policy
statement. (The policy statement, which was issued in 1987, is reproduced here as
Appendix A.)  The policy statement recognizes that information is an Agency asset
and that the EPA is highly dependent on its information resources  to carry out
program and administrative functions in a timely, efficient, and accountable manner.

The  policy  statement   formally   establishes  a   comprehensive,  Agency-wide
information   security  program  and  describes  individual  and  organizational
responsibilities under the program.  Two procedural manuals which explain to EPA
managers  and staff how  to  comply with these responsibilities  have now been
developed.

This is one of the two manuals and  it deals exclusively with personal computer (PC)
security. The second manual deals comprehensively with all types of information
assets (paper records, mainframes and minicomputers, information systems, PCs,
and word processors).  Because PC security affects the most employees and is a
relatively new area of security vulnerability, it is important to handle it separately  so
that the PC procedures will be accessible and will not get lost in  discussions  of
mainframe or software development security.

Each manual begins with  similar introductory sections.  Information security and
information sensitivity are defined  in terms of the three  objectives  of the  EPA
program, which are to maintain information availability, integrity, and confidentiality
The information security problem  is then described in terms of threats to the
objectives.

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Information Security Manual for PCs	^^^        12/15/89

Each manual is structured to allow the reader, whether manager or staff member, to
tailor it to his/her own particular  security situation by completing one or two
worksheets and by reading selected portions of the text.  Specifically, each reader
works through a sensitivity evaluation  table to determine if he/she has  sensitive
information.  If not, only minimal security controls need to be implemented.  If the
reader does have sensitive information, he/she  uses a worksheet to identify why the
information is sensitive and which of the three security objectives are relevant. The
reader is then referred to later sections of the manual as appropriate. For example,
there is a subsection on safeguards for maintaining the availability of critical PC
applications.

Because a common problem in information security is determining exactly who is
responsible for what aspects  of  security,  each  manual devMes  a chapter  to
information security roles and responsibilities.  While the manu Js try to be as user
friendly as possible in explaining to readers how to fulfill those responsibilities, the
manuals  are not painless.  To ensure that information resources are adequately
protected, the manuals  describe three different control processes. The processes
establish a structure of security checks  and balances by approaching security both
from an  equipment perspective and from an application or information system
perspective.

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 Information Security Manual for PCs
                                                        12/15/89
                      TABLE OF CONTTENTS
Section
                                                        Page
 1 .  GENERAL INFORMATION
2. PC SECURITY ROLES AND RESPONSIBILITIES ..................................... 2-1

3. MINIMAL CONTROLS FOR ALL PCs AND PC LANS ................................ 3-1

4. DETERMINING THE NEED FOR ADDITIONAL CONTROLS ..................... 4-1

5. PERSONNEL SECURITY AND TRAINING ................................................ 5-1

6. MAINTAINING INFORMATION AVAILABILITY .......................................... 6-1

7. PRESERVING INFORMATION INTEGRITY ............................................... 7-1

8. PRESERVING INFORMATION CONFIDENTIALITY .................................. 8-1

APPENDIX A:   POLICY [[[ A-1

APPENDIX B:   APPLICATION RISK ANALYSIS AND
             APPLICATION CERTIFICATION ......................................... B-1


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information security Manual for PCs	12/15/89

                      1.  GENERAL INFORMATION

1.1   PURPOSE, SCOPE, AND APPLICABILITY

In accordance with the Agency's Information Security Policy, this manual establishes
information security procedures for personal computers (PCs) and provides overall
guidance  to  EPA managers and staff in implementing those procedures.  The
security controls specified in this manual are designed to ensure that information on
PCs is  adequately protected  and that EPA organizations and employees are in
compliance with all requirements of the policy.

This manual  addresses PC  security only.  A single PC  installation is generally
comprised of a microprocessor,  a video monitor, and various peripheral devices for
entering, storing, transmitting, and printing data. The PC installation may process in
isolation as a stand-alone personal tool and/or it may function as a smart terminal in
a communications configuration (such as PC to mainframe or in a local  area
network).  This manual does not apply, however, to other types of microsystems
such as word processors (for example, Lexitrons) or dumb terminals (those that are
not programmable).   Information security for these devices  is dealt with in the
Agency's comprehensive "Information Security Manual."

Consistent with the  Information  Security  Policy,  this manual applies to  aJI  EPA
organizations and employees that use PCs.  It  also applies to the personnel of
agents  (including contractors  and  grantees) of the  EPA who are involved  in
designing, developing, operating, or maintaining Agency information and systems on
PCs.

The specific purposes of this manual are as follows:
    •   To save organizations money by making sure that only focused, cost-
        effective security safeguards (or controls) are implemented
    •   To protect organizations and individuals  from the embarrassment of an
        unauthorized  disclosure  or from the disruption that would result if crucial
        information were destroyed
    •   To help organizations meet internal control review requirements by providing
        them with a sound basis for assuring that automated PC information systems
        are adequately protected
    •   To assist staff in developing the system documentation required by the "EPA
        System Design and Development Guidance"
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 information Security Manual for PCs                                 12/15/89

      •   To help organizations meet the security reporting requirements of the EPA
         PC planning process
      •   To enable organizations to undergo successfully  any security audits that
         may be conducted by the Office of the Inspector General.

 1.2   INTRODUCTION TO THE EPA INFORMATION SECURITY PROGRAM

 Through the Information Security Policy, the EPA has established a comprehensive,
 Agency-wide information security program to adequately safeguard the Agency's
 information resources.  (The policy, which is Chapter 8 of the EPA's Information
 Resources Management Policy  Manual, is  reproduced here as Appendix A.)  The
 concept of adequacy means that security controls should be neither overapplied nor
 underapplied.    Overapplication  wastes  financial  and  ADP   resources,  and
 underapplication exposes the information to various security threats.

 The policy categorizes information  and applications  (or systems' as being either
 sensitive or not sensitive.   Sensitive information means information that requires
 protection  due to the loss  or harm  that could result from inadvertent or deliberate
 disclosure, alteration,  or destruction  of the  information.  Examples of sensitive
 information include Confidential Business Information (CBI), Privacy Act Information,
 and data  critical to  the  performance of primary Agency missions. A sensitive
 application is an application that processes sensitive information, or is an application
 that requires protection due to the loss or harm that could result from the improper
 operation or deliberate manipulation  of the application itself.

 In short, information  security involves  the  precautions taken to protect sensitive
 information resources from potential  loss and misuse.  The three major objectives of
 the EPA  program, as illustrated in Exhibit 1-1, are to maintain:
             Information Availability
             Information Integrity
             Information Confidentiality

The  availability objective  is associated with  information  where the loss  of the
information would  cause serious problems, either because it would be costly to
replace the information or because it  would  be difficult to  function without the
information. Thus, availability involves both  the dollar value and the time value (or
"crfticality")  of the information.  An  example of an Agency information system or

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imormauon becuniy Manual Tor
                                                                   \fj
                                EXHIBIT 1-1

                   INFORMATION SECURITY OBJECTIVES
                    Prevent
                    Information
                    Loss
                                     AVAILABILITY
                                    CONFIDENTIALITY
         Prevent
         Information
         Corruption
                                                Prevent
                                                Information
                                                Disclosure
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information becurtty Manual for PCs	12/15/89

application  where  availability is important  is  the  Resource Conservation and
Recovery Information System (RCRIS).

The integrity objective is associated with information or applications where accuracy
and reliability are  of  particular concern. In short,  integrity  is concerned with
protecting information from corruption.  An example of an Agency information
system where integrity is important is the Integrated Financial Management System
(IFMS).

The confidentiality objective is concerned with information where disclosure would
be undesirable or unlawful.  Examples of information of this type include  Toxic
Substances  Control  Act  (TSCA) Confidential  Business  Information  (CBI)  or
personnel files.

As Exhibit 1-1 indicates, a particular application could involve only one objective or
could involve some combination  of objectives. For example, a particular data base
could contain information critical to a primary Agency mission and yet contain no
confidential  information.   In other words, while   availability is an  objective,
confidentiality is not a factor and the  information in the data base could be widely
disseminated without any damage resulting from disclosure.  On the other  hand,
another data base could be both critical and confidential.

1.3   THE PC SECURITY  PROBLEM

The expanding use of personal computers is creating major new opportunities for
productivity improvement at the  EPA.  At the same time, however, this expanding
use of personal computers is placing new information security responsibilities on
office managers,  research personnel,  and others not previously recognized as
information  processing  professionals.  This  decentralized  processing of Agency
information means that mainframe and minicomputer processing installations can no
longer be relied upon to protect all automated Agency operations.

The nature of the PC security problem is yiustrated in  Exhibit 1-2.  A wide range of
intentional  or unintentional events can threaten information  being  stored and
processed on a PC. These threats include:
    •  External and environmental threats, such as fire, water damage, or power
       failure
                                    1-4

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                  EXHIBIT 1-2

            THE SECURITY PROBLEM
           Environmental Threats
                                 Hardware & Software Errors
Malicious Actions
              ! Software
                &Data
              ! Controls
Equipment
& Physical
 Controls
Administrative
  Controls
                     INFORMATION
                     RESOURCES

                       Programs
                       Data
                       Equipment
                      1-5

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 • Ill Wl I I I
     *  Hardware and software error, such as disk or operating system failure
     -  Operations error, such as accidental user modification or erasure of data
     •  Malicious actions, such as theft or data sabotage.

 How vulnerable a particular PC  is to these threats depends on two basic factors.
 The first is the type or nature of information being processed, that is, the relevance of
 each of the three security objectives.  The second factor is the environment in which
 the PC is processing the information, for example, whether the PC is stand-alone or
 is part of a network.  Information security involves identifying threats and applying
 controls to prevent  threats from  being  realized. When threats  are realized  (for
 example, disclosure or damage/loss of information),^ three security objectives are
 not achieved.

 Certain PC characteristics pose special problems in information security. In general,
 these include the following:
     •  Personal computer systems software is typically rudimentary and  affords
       little or no protection to information and programs.
     •  Personal computers typically lack the built-in hardware mechanisms needed
       to isolate users from each other and from certain system functions (such as
       reading and writing to memory).
     •  PC information is typically in the form of reports, spreadsheets, lists, and
       memoranda.   These relatively "final" forms mean that PC data are more
       readily accessed and understood by unauthorized users than are data in
       larger computer systems.

 1.4   STRUCTURE OF THIS MANUAL

 PC security manuals are typically organized by type of security and include chapters
 on physical security, data security, communications security, and the like.   While
 such manuals provide good technical discussions of security controls, they typically
 overwhelm the reader  with a  hodgepodge of safeguards  that cause uncertainty
 about exactly which safeguards should be implemented.  In addition, these manuals
 often provide little in the way of overall implementation guidance.

This  manual  is  structured  in  a  completely different manner.   In  essence, it is
organized to allow each reader, whether a manager or staff member, to tailor it to
his/her own particular security situation.  In a very real sense,  the manual allows
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            oecuruy Mdiiudi ior rus
each reader to work through his/her security problem by completing one or two
worksheets and by reading selected portions of the text.

Following the introductory material presented in this first section, Section 2 concerns
itself  with individual and organizational information security responsibilities and
should be read by all EPA managers and staff using PCs. Because it is not easy to
coordinate the diverse elements  of an information  security program, Section 2
recommends that one  management  official, the Senior Information  Resources
Management Official (SIRMO), be the focal point for information  security in each
major EPA organizational unit.
                                               V
Section 3 describes minimal security controls to be used for all PCs, regardless of
the processing environment or the type of information.  Section 3 should also be
read by all F PA managers and staff.

Section 4 is the last section that should be read by all EPA managers and staff.
Section 4 analyzes the need for additional security controls by determining whether
or not the reader has sensitive PC applications.

Based on the determination of sensitivity, the reader is referred to  Sections 5-8, as
appropriate.  Section 5 highlights key  personnel security considerations for those
with sensitive I 'C applications. Section 6 addresses security procedures for those
needing to maintain availability.  Sections 7  and 8 present security procedures for
those needing to preserve integrity and confidentiality, respectively.

1.5   RELATIONSHIP TO OTHER SECURITY PROCEDURES

In this  manual, the Office of  Information  Resources Management  (OIRM) is
establishing overall, Agency-wide security procedures for  safeguarding EPA PCs.
Other  EPA organizations  have  developed  specialized  procedures  in  particular
information security areas.  As an important example, the National Data Processing
Division (NDPD) in Research Triangle  Park issues technical policies concerning
systems (for  example, PC  local  area  networks)  supported and  approved by it.
These policies are contained in the "NDPD Operational Policies Manual." In addition,
EPA organizations with  statutory authority  for certain types of  information (for
example, the Office of Toxic Substances for TSCA CBI) issue security procedures
dealing exclusively with a certain type of information.
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imormauon aecuriiy Manual tor PCS	                      12/15/89

Nothing contained in this manual is intended to contradict or replace the specialized
security procedures of these other organizations.  Those specialized procedures
expand upon the core procedures presented in this manual. EPA organizations that
issue such procedures must ensure that they are consistent with this manual. EPA
employees must make sure they adhere to all such specialized procedures, as well
as to the procedures presented in this manual.
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          2.  PC SECURITY ROLES AND RESPONSIBILITIES

2.1    BACKGROUND

Information security  involves much  more than technical hardware and  software
issues.   Above  all,  a successful  information  security  program  needs  strong
organizational and administrative controls. Administrative/managerial factors such
as top management support and employee awareness contribute significantly to
program success. An information security program needs to involve all employees
? Jid to be a part of the day-to-day operations of an organization.

Because  of  these  factors,  the  Information Security Policy assigns  information
security responsibilities to top management, to supervisors, and to employees. This
manual is intended to explain to EPA managers and staff how to comply with these
responsibilities in a way that is not overly burdensome on programs and individuals.
Th3  remainder  of  this section describes  a suggested  overall  framework  for
implementing the Information Security Policy as it relates to PCs.

The framework of security roles  set  forth in  this section is not mandatory. While
programs must meet the requirements of the Information Security Policy, they may
find they are able to do so by creating somewhat different roles than those defined
here.  OIRM recognizes that program.1; may need to modify the framework to meet
unique program needs.   The  framework  is  not  meant  to be  inflexible  and
bureaucratic; instead, its intent is to assist programs and individuals in implementing
adequate protection of sensitive information.

2.2    PC SECURITY ROLES:  AN INTRODUCTION

A common problem in information security is determining exactly who is responsible
for what aspects of security.  In determining accountability for information security, it
is extremely useful to start with a framework of owner/user/custodian.  Throughout
this manual, specific  security actions  are cast  in terms of this  framework, while
oversight and coordinating  actions  are  the responsibility  of management. The
framework is described in detail in the next subsection.

It is  important  to  recognize  that  there  may  not  always  be  a  one-to-one
correspondence between individuals and roles.  In other words, at times it may be
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information security Manual tor PCs	         12/15/89


 more efficient to have several individuals share the responsibilities of a role. Again,
 the framework described here is meant to be a flexible implementation tool.

 2.2.1 Owners. Users, and Custodians


 These three roles are defined as follows:

     •   Application (or Information System) Owner:  The owner of the information is
        the  individual or organization  who  creates and sponsors it.  Ownership
        involves  authority  and  responsibility for  the  information,  either in a
        programmatic or administrative  sense.  For example, the Office  of Solid
        Waste and  Emergency Response is the owner of RCRIS.  The Office of
        Administration and Resources Management is  the owner of IFMS.  The
        owner determines the sensitivity  of the application (or information system),
        assigns custody of the application, and decides who will  be allowed to use
        the application.  Consulting with the custodian  as appropriate, the owner
        specifies and approves security controls, and ensures that the application is
        protected on an ongoing basis.  The owner also determines backup and
        availability requirements and communicates them to the custodian.

     •   Application (or Information System) User:  Users are  individuals who  are
        authorized by the owner to access an application or collection of information.

     -   PC Custodian: The custodian is  the individual to whom the PC is assigned.
        This is the person responsible for the PC in the property management sense.

These roles  are  not  always discrete; the owner can be the principal user and
custodian of the information. For example, an individual who develops an end-user

application for stand-alone processing on his or her own PC is at  once the  PC
custodian, application owner, and application user.

2.2.2 The SIRMQ as Focal Point


Because information security covers a variety of information resources and so many

different employees and supervisors, it is  important to have one management official
in each major organizational unit who can coordinate the security program for that

organization. This individual will serve as a security focal point by identifying ail  PC

owners, custodians,  and users,  and by  disseminating  security-related information

throughout the organization. While each Primary Organization Head (as defined in

the policy statement) may designate whomever he/she wishes for this coordinating
role, the SIRMO is strongly recommended for this  function.  The designate may

delegate portions of this PC security function (for example, identifying PC owners,

users, and custodians) to other  knowledgeable individuals in the organization as
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imormation security Manual Tor HUS	          12/15/89

long as the Primary Organization Head approves and as long as the coordinating
role is retained.

2.2.3 Managerial and Administrative Roles

In addition to owners,  users, custodians and SIRMOs, the implementation of the
security procedures in  this manual also requires the involvement of several other
individuals in five oversight roles. The first four of these roles exist at present whfle
the remaining role is unique to the security program. The five roles are:
     •  Primary Organization Head
     •  First-line supervisors
     •  PC Site Coordinators
     •  Local Area Network (LAN) System Administrator
     •  Certifying  Official:   Management  Official(s)  appointed  by the  Primary
       Organization Head. This official certifies that the security safeguards that are
       in place for each sensitive application are adequate.

2.3  ASSIGNING RESPONSIBILITIES TO THE  SECURITY ROLES:
     IMPLEMENTING  PC SECURITY

Ensuring that PC information resources are adequately  protected  involves three
different  management  control processes.   First, basic,  common-sense  security
measures need to be implemented for each PC, regardless  of whether or not it
processes sensitive information. Second, an application certification process needs
to be established  to determine the  sensitivity of each PC  application and to certify
that the security safeguards for each sensitive application are  adequate.  Third, an
installation risk analysis process needs to be established to make sure that the
security measures in place for each  PC adequately protect the sensitive applications
stored and processed  on the PC.   The second and third processes establish a
structure of security checks and balances.  They approach information security both
from an installation or equipment perspective and  from an application (or information
system) perspective.

Each of the three management control processes is described  in more detail below.
Table 2-1 then lays out the security responsibilities associated with the processes on
a role-by-role basis.
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Information Security Manual for PCs
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                          TABLE 2-1
       IMPLEMENTING A MANAGEMENT CONTROL PROCESS FOR
         INFORMATION SECURITY: RESPONSIBILITIES BY ROLE
Role
Primary Organization Head
SIRMO
Application (or Information System Owner)
PC Custodian
Application (or Information System) User
Supervisor
PC Site Coordinator
Certifying Officer
LAN System Administrator
Responsibilities
Implements the organization-wide security pro-
gram. Designates Certifying Officer(s).
Coordinates the organization-wide security
program. Identifies PC owners, users, and
custodians.
Determines information sensitivity. Assigns cus-
tody. Initiates application certification process.
Authorizes users. Specifies and approves
security controls. Specifies backup and avail-
ability requirements. Makes sure users and
custodian adhere to security requirements.
Responsible for the security of his/her equip-
ment. Must implement minimal controls.
Performs risk analysis.
Adheres to security requirements of owner.
Reviews application certification form. Ensures
employees fully comply with information
security responsibilities.
Ensures minimal controls are in place. Advises
owner on application certification process.
Certifies sensitive applications. Advises owner
on application certification process.
Coordinates the selection of security safe-
guards for networks.
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2.3.1  Minimal Controls

Section 3 describes the safeguards that need to be in place to ensure the basic
physical and environmental protection of the PC and its magnetic media. Section 3
also sets forth administrative procedures governing the use of PCs and commercial
software. Minimal controls are implemented by custodians or users as appropriate
with oversight provided by the cognizant PC Site Coordinator.

2.3.2    Sensitivity Determination. Automated Application Risk Analysis.
         and Application Certification
                                                  t
                                                  i
 The requirements  of  the  certification  process, including the completion  of the
Application  Certification Worksheet, are described in detail  in Appendix B.  Key
elements of the process are summarized below:

     •   Each Primary  Organization Head  will designate one  or more Certifying
        Officials for his/her organization.

     •   Each application owner will determine the  sensitivity  of each of his/her
        applications.   This  determination will be made in  accordance with the
        instructions set forth in Section 4 of this manual.

     •   Each sensitive application must undergo initial certification, and then review
        or  audit leading to recertification every three years.  The certification or
        recertification process will begin with the application owner's completion of
        the  Application Certification Worksheet. The worksheet  will capture basic
        information on application sensitivity, security specifications, design reviews,
        and tests of security safeguards.

     -   When the worksheet is complete, it will be forwarded through the owner's
        immediate   supervisor  to   the   cognizant   Certifying   Official   for
        approval/disapproval.

     -   The  worksheet will be  used by the  application owner to communicate the
        sensitivity of the application and the  required security procedures to the
        users of the application.

     •   It should be noted that in developing  the worksheet  the owner performs a
        qualitative risk  analysis, that is, the owner assesses the relative vulnerabilities
        and threats to the application and then  specifies safeguards.

 2.3.3  Installation Risk Analysis Process

 All Agency PCs are required to  undergo a risk analysis. A risk analysis is a means of

 measuring and assessing the relative vulnerabilities and threats to an installation.  Its

 purpose is to  determine how security safeguards  can  be  effectively applied to

 minimize potential loss.  In everyday terms, a risk analysis  is  a  procedure for

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 Identifying what could go wrong, how likely it is that things could go wrong, and what
 can be done to prevent them from going wrong.

 There are two accepted methods for performing a risk analysis-quantitative and
 qualitative.  For Agency PCs, a qualitative  risk analysis  approach will be  used.
 Simply put,  this  method  handles typical  situations quickly  and efficiently by
 combining the  analysis of risks with safeguard selection. It consists of the following
 basic components:
     •   Determine  what  information  is sensitive  and non-sensitive.     This
        determination will be made in accordance with fie instructions set forth in
        Section 4 of the manual.   If the PC does not process any sensitive
        information, the risk analysis is at an end and only  minimal controls need to
        be implemented.  If it does, categoriz3 the sensitive  information, for example,
        "confidential" sensitive.
     •   For each category of sensitive information, determine the level of sensitivity,
        for example, highly confidential.
     -   Decide on an overall set of safeguards or security controls to use.
     •   Tie subsets of those safeguards to particular categories of information and
       to levels of sensitivity.

Implementation of  an installation risk analysis  is the responsibility  of the  PC
custodian. By working through this manual, an informal and qualitative  risk analysis
is performed.  The custodian need only adhere to the procedures presented in this
document and complete the Risk Analysis Worksheet described in Appendix C.  No
special analytical process has to be undertaken.

Under certain  circumstances, custodians  may feel that more rigorous, quantitative
methods are warranted.  OIRM does not wish to prohibit such thorough analyses.
Interested custodians should  review the last section  of Appendix C for  more
information.
2.4  STREAMLINING THE IMPLEMENTATION OF PC SECURITY

In establishing these management control processes, OIRM  wants to achieve
adequate PC security throughout the Agency in a way that does not unduly burden
programs and individuals. To that end, organizations may find that the following can
help streamline the management control processes discussed above:
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Information Security Manual for PCs                                 12/15/89
        In some organizations, one individual (or a handful of individuals) may be
        knowledgeable enough about the organization's PCs and the information
        contained on them to function as a composite or aggregate owner, user, and
        custodian for  the organization.  In other words, the  individual has the
        requisite knowledge to complete the organization's Application Certification
        and Risk Analysis Worksheets, not just the worksheets for his/her own PC
        and applications.    This  aggregated approach  is  consistent  with the
        owner/user/custodian  framework  and  is  an  acceptable approach to
        achieving compliance.

        In  identifying  applications for sensitivity determination and  certification,
        individuals /organizations may find that some applications are subsystems or
        "children" of larger or "mother" applications.  Simflarty, some  applications
        may be so related that the boundaries between them are fujzy and that for
        the  purposes  of this document they  can be thought  of as  one.  In
        implementing the certification process, such sensitive applications may be
        combined into a single sensitive application. A key test of whether or not a
        se isitive application  has  been properly  delineated is whether or not the
        questions on the certification worksheet can be  meaningfully answered.  If
       the responses are full of exceptions and two-part answers, the  aggregation
        is probably incorrect.
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        3.  MINIMAL CONTROLS FOR ALL PCs AND PC LANS


3.1   INTRODUCTION


The purposes of this section are:  1) to describe the security measures that need to
be taken to ensure the basic physical and environmental protection of  PCs and

magnetic media, and 2) to set forth administrative procedures governing the use of
PCs and commercial software. The dollar value of the typical PC configuration is

usually several thousand dollars.  All of the measures described in this section can
be implemented at little or no cost, ensuring their pverall cost-effectiveness.  The

emphasis here is on common-sense  measures  that are justified without  a risk
analysis.


The responsibility for making sure these controls are in place rests with custodians
or  users,  as indicated below.  Cognizant PC Site  Coordinators should ensure
compliance with these requirements through periodic, informal inspections.


3.2   PHYSICAL CONTROLS


Agency physical security procedures  issued by  the Facilities Management and
Services Division (FMSD) state that:

            'All  office equipment—should be locked  up when not in use...Cables  and
            anchor  pads can be  used to secure typewriters,  calculators, computer
            peripherals, and the like.  See SCR 1-08 for information about locking devices.*
            (Directives Volume 4850-1, SCR 1-06, page 7)


Consistent with these procedures, the following controls  for PCs are required  to

prevent theft and physical damage. PC custodians are responsible for ensuring that
these controls are in place.

    •  Locate PCs  away from heavily travelled  and easily accessible areas to the
       extent possible.

    -  When possible, install the PC in  a locked room, making sure the lock is used
       whenever the room is unoccupied (and not just at night). If the PC cannot be
       installed in a locked room, a locking device such as a locking anchor pad or
       hardened cables can be used.  For further information or assistance, contact
       the Security Management Section of FMSD.

    •  All IBM  PC/AT  and most compatible microcomputers  are delivered with
       standard system locks that prevent the system from being operated and
       prevent the cover from being removed, guarding against component theft.
       Use  these  locks.   When adding  valuable  expansion boards (such  as

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Information Security Manual for PCs                                 12/15/89
       additional memory or graphics interfaces) to PCs that do not have factory-
       installed locks, install a cover lock.

       Place computers and peripherals on stable and secure platforms away from
       objects that could fall on them.

       Portable  PCs  require  additional security considerations  because  their
       portability increases  their vulnerability to theft.  In addition to the physical
       security measures already mentioned, store all portable PCs in  locked
       cabinets when not in use.  For further information or assistance, contact the
       Security Management Section of FMSD.  Assign a person who tracks the
       location of the  portable PCs on a regular basis,  logs them out for use to
       authorized users, and ensures the portable PCs have been returned to the
       locked storage  area when  not in use. Morepver, any employee removing a
       portable PC from an EPA building for off cial use must have a property pass.
3.3   ENVIRONMENTAL CONTROLS


PC custodians are responsible for ensuring that the following controls are in place:

    •  PCs are sensitive  to surges in  electric'J power.  To provide  protection
       against current surges, install a surge protection device. Good quality, multi-
       stage surge protectors are available for under $100.

    •  Do not install the PC in direct sunlight or in  a location with extremes of hot
       and cold temperatures (less than 50 degrees Fahrenheit or greater than 100
       degrees Fahrenheit).  Do not leave a portable PC  in a parked car, which
       would also subject it to temperature extremes.

    •  Computer equipment (and media) are sensitive to contamination from dirt,
       smoke, or magnetic fields. Do not eat or drink in the immediate vicinity of the
       PC. Per the Agency's smoking policy, do not smoke in the vicinity of the PC.
       (Smoke is drawn into the yents and through the disk units, covering the units
       with tar. Tar reduces the life of the disk and the read head.)

    -  To avoid problems  from dust and possible overhead water leaks, protect
       computer equipment with inexpensive plastic covers when not in use. Install
       the PC as far as practical from overhead water pipes or sprinkler heads.

    •  Control static electrical charges  by placing  antistatic  mats under  the
       computer or  workstation or by using antistatic  sprays.  (Laundry fabric
       softeners containing antistatic ingredients can be used for this purpose, and
       they are  quite inexpensive  when compared to special  purpose antistatic
       sprays). Because the problem of static electricity is increased when the air is
       extremely dry, it can be reduced by the use of humidifiers  if these  are
       available.
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 3.4    MAGNETIC MEDIA CONTROLS


 At present, virtually all information on microcomputers is stored on magnetic media
 in the following forms:

     •   Diskettes

     •   Fixed disks inside the computer

     •   Cartridge tapes

     •   Removable disk cartridges (for example, Bernoulli cartridges).
                                               V
 PC users need to treat the magnetic media with special care.  Flexible diskettes are
 especially susceptible to damage.

     •   Keep all magnetic media away from all electrical devices and magnets to
        avoid magnetic fields.  This includes magnetic paper clip holders, building
        passes or  credit  cards with magnetized strips,  PC hard drive units, and
        telephones.  For example, if a diskette is left on a desk and a telephone is
        placed over the diskette, data on the diskette  may be destroyed when the
        telephone rings.

     •   Do not flex diskettes.  Bending the media can damage the delicate surfaces
        and destroy data.

     •   Store diskettes in their jackets as  soon as they are removed from the
        computer.  The jackets are made of a special material that is intended to
        protect the diskette.  Cartridge tapes and removable disk cartridges should
        also be stored in their original containers.

     •   Never touch the surface of the diskette platter.

     •   Do not write on a flexible diskette with a pencil or hard-tipped pen. Use only
        a soft-tipped marker.

     •   Keep diskettes in a disk file container when not in use.  Dust and other
        paniculate materials can scratch and damage the disk.

     •   To prevent permanent loss of data on the fixed disk drive, all files need to be
        backed up  and the heads need to be parked before a PC is moved.  Some
        portable  PCs also may require that the heads be parked  and/or a disk
        inserted into the disk drive when transporting the portable.
3.5   BACKUPS


When it comes to making backups of data and programs, it unfortunately seems that

experience is the best teacher.  A user often needs to lose a key file before realizing
the importance of regular backups.


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For certain types of applications (discussed later in Sections 4 and 6), routine and

systematic backups are of particular importance and this manual sets forth specific

backup procedures. As a minimal control, however, users should be in the habit of
regularly backing up their work.  While a precise set of criteria for determining how

often to make these backups cannot be provided, how active the data file is and how
long it took to create are  key factors to consider.  The appropriate backup method

can vary and can include floppy disks, cartridge tapes, removable disk cartridges, or
remote hosts such as minicomputers.


Users  should note  that if they are using their PC as a terminal for prc cessing data
and  programs stored at  another  site (such as a minicomputer, LAN file server, or
mainframe facility),  that site may already be backing up tha data on a regular basis.

Consult the manager  of the remote facility or the LAN' System Administrator for
information.



3.6   SOFTWARE COPYRIGHTS/LICENSES AND MASTER COPIES

Owners and users  who purchase commercial software must follow the procedures
below.  Supervisors are  responsible for ensuring that their employees  adhere to
these procedures.

     •  Commercial software is typically under copyright and accompanied by a
       licensing agreement which specifies whether  copies may be made.  EPA
       employees  must  adhere  to these licensing  agreements.   Unauthorized
       duplication  of software is strictly  prohibited and is not condoned  by the
       Agency under any circumstances.  In general, there are two types of licenses
       -- single-machine  and site. A single-machine license allows the user to install
       the master copy of the software on his/her PC only. With a site license, the
       software may be installed on more than one PC, typically for a higher fee. A
       copyright means that  any  unauthorized duplicating,  selling,  or  other
       distribution  of the software is a crime. Willful violations of U.S. copyright law
       can result in significant penalties (civil damages of up to $50,000 in addition
       to actual damages plus criminal penalties of up to one year in jail and/or a
       $10,000 fine).

     -  Software purchased by the EPA must be used  exclusively on PCs owned by
       the EPA.

     •  Software licensing  agreements  should  be  signed  upon  receipt  and
       immediately filed with the vendor.  A copy of the agreement  containing the
       registration  number should be filed in a safe place. Returning the agreement
       to the vendor will register the purchase and  may result in  free user
       assistance,  free or reduced price software upgrades and other advantages.
       Registration of the software will also provide the basis for getting assistance
       from the manufacturer if the software is lost, stolen, or damaged.


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     •   Already  established  OIRM  procedures concerning master copies of PC
        software state that each Primary Organization Head needs to establish a
        central   repository  for  the  organization's  master  copies  to  ensure
        accountability and control.  The WIC can be  used for this purpose  if an
        organization executes an Operational Service Agreement for Archiving of PC
        software.

3.7    UNAUTHORIZED USE OF PERSONAL COMPUTERS AND SOFTWARE

EPA PCs and associated software are for official EPA business only. Appropriation
of EPA-owned software for personal use, whether done by unauthorized copying or
by actual removal of the master software, is prohibited.  Use of Agency computers is
not allowed for personal business of any kind, even if it is done on the employee's
own time.  Training and practice on EPA PCs should be done using  work-related
examples.  Employees who use EPA PCs and software for other than official Agency
business are subject to disciplinary action ranging from a reprimand to dismissal.

3.8    NON-EPA SOFTWARE AND VIRUSES

Computer viruses have received a great deal of attention in the press. While some of
the coverage is  sensational,  it is clear that the problem  is real and that risk does
exist. The threat of viruses has made the need for regular backups (per Section 3.5)
even greater.

In general, a computer virus is an extra program hidden within an apparently normal
program or software package referred to as the virus "host" or "Trojan Horse". Like a
biological virus,  the  computer virus has two  important characteristics - it can
replicate itself and it can cause harm or mischief.  This replicating ability means that a
virus can quickly spread via shared diskettes, networks, electronic bulletin boards, or
file servers as programs  or files are stored, executed, uploaded or downloaded.
Potentially infected host software includes operating system tools such as an editor
or file utility, data base management software, or spreadsheet macro languages.

Some viruses are relatively harmless and only flash a message on the monitor before
destroying themselves.  Others are truly malicious and modify or destroy programs
and data.  To detect and combat viruses,  a number of specialized programs or
software "vaccines"  have been  developed.   Because various computer  viruses
operate in different ways, no single vaccine is currently effective against all of them.
Indeed, some of the vaccines have harbored viruses themselves.

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Information Security Manual for PCs	12/15/89

Under these circumstances,  it is not possible  to develop a  set  of generic,
straightforward  procedures to ensure the integrity of non-EPA or public domain
software.  Consequently, EPA employees should not install non-EPA or  public
domain software on their PCs without the express approval of their SIRMO  or the
SIRMO's designate. In addition, EPA employees and contractors who use PCs or
LANs supported and approved by the National Data Processing Division (NDPD) are
also subject to the virus prevention policies set forth in the "NDPD Operational
Policies Manual." Those policies include recommendations related to new software,
backups, and regular checks for program/file size changes.

Readers may also wish to consult the additional guidance presented in the National
Institute  of  Standards  and Technology Special  Publication  500-166, entitled
"Computer Viruses and Related Threats: A Management Guide."  The puWicat on,
which  was issued  in Augus* 1989, provides  general guidance for managing the
threats of computer viruses and unauthorized use.  It deals with different computing
configurations such as personal computers and networks. A copy is available in the
EPA Headquarters library or through the Government Printing Office.
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     4.  DETERMINING THE NEED FOR ADDITIONAL CONTROLS

 The minimal controls described in Section 3 are required for all Agency PCs. The
 purpose of this  section is to determine whether  or not  additional controls are
 necessary.

 Application  owners use this section to evaluate the sensitivity of each of his/her
 applications.   Determining  sensitivity  is an owner responsibflity.    If sensitive
 applications are owned, Section 6-8 need to be consulted, to develop the information
 required for the  application certification process arid the Application Certification
 Worksheet (see Appendix B).

 Application  useis review  this section  to develop  a working understanding  of
 information sensitivity.  Users can also use this section to determine the sensitivity of
 applications not yet evaluated by the owner (that is, existing applications that are
 undergoing certification). Section 6-8 should then be reviewed, as appropriate.

 PC Custodians and  LAN System Administrators review this section to develop a
 working  understanding of information sensitivity.  Custodians then combine this
 understanding with owner sensitivity designations to determine the number and type
 of sensitive  applications being processed by  users of his/her installation, and to
 identify the installation processing  environment. Sections 6-8 then need to be used
 to determine what security controls must be in place and to develop the  information
 needed for the Risk Analysis Worksheet (see Appendix C). This process constitutes
 a qualitative risk analysis and will ensure that adequate disaster recovery/continuity
 of operations plans are formulated.

 4.1   DETERMINING SENSITIVITY AND THE TYPE OF INFORMATION

 The reader should review Section 2.4 before proceeding.  That section contains
 information on combining applications for sensitivity determination purposes.

The questions presented in the sensitivity evaluation table on the next page (Table 4-
 1) are designed to determine whether a particular application is sensitive.  To use the
table, first read through all 11 questions presented in columns (1) - (11) of the table.
                                   4-1

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Nameol
Application?
Information
•EXAMPLE-









QUESTIONS
(')
National
Security
Mormallon?










P)
Crtkudo
Performing a
Primary
Agency
Mission?
YES









(31
LI* Critical?










<«)
Financial
Whore
MISUM COUW
Causeless?










(5)
Auto mated
OocWon-
Maklng
AppScBtbn?










(6)
Subject to the
Privacy Ad?
YES









(1
Confidential
Business
Information?










n(4)



 Question (5)
                                                                                                                                                                                    H

                                                                                                                                                                                    O
                    Anwwr YES H disablement or unavailability of the application, or tfie low. rampromts*. or undmlred •Iteration of the information couto jkcpardlze the Agency's abdrty to pertorm a primary
                    mission.



                    Answer YES H (he toss of Information or disruption of the application could jeopardize human (He or welfare.



                    Relates to check issuance, funds transfer, etc.. where misuse could cause loss.



                    Answer YES H the application makes unsupeiytsed automated decisions based on programmed criteria (for example. Issuing checks, ordering supplies, or performing similar asset
                    ae*«jnting/corrtrol functions) and If the wrong automated decision could cause toss                  i        P-      n       .      TI~HV      r~-     -w



Ouwtton (10)        *"•*•'VES " "* h an «PpHeattonf1nformBtlon of "High Value" to the Agency or a particular organization. The term "High Value" must be defined by the owner of fhe Information or

                    appHcatton. While a precise set of criteria for determining High Value cannot be provided, the cost of replacing the information and the problems that would result from doing without the
                    Information are primary factors to consider.                                •--»-••                     r-                             •«



Question (11)       ****'*** H: M »»." •n»"wred NO to an other questions, and (2) this is an applicainrvlnformatton whose toss would acutely embarrass the Agency, subject the Agency to rogation, or
                   impair the long-run ability of the Agency to fulfill its mission.
                                                                                                                                                                                               cn

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 If all  questions  can be answered "No" for all applications, the  remainder of this
 manual does not apply.  If any question can be answered "Yes" for any application,
 continueto determine how to protect the sensitive application(s) by completing the
 table.  (After completing the table, make sure to have it reviewed as described in
 Section 4.4.1

 The table has been designed as a worksheet for use in evaluating sensitivity. To use
 the table,  list in the first column the name  of each application or collection  of
 information for which at least one question can be answered "Yes".  For each listed
 application or collection of information, answer each question.  A sample entry is
 provided.  (Leave the last three columns (security objectives) blank for the time
 being; use of these columns is explained below.)

4.2  DETERMINING RELEVANT SECURITY OBJECTIVES AND THE DEGREE
     OF SENSITIVITY

The next step is to determine how sensitive each sensitive application is and which
security objectives are relevant.   Table 4-2 on the next page maps each type  of
information to its corresponding objective(s) and sensitivity level (that  is, high versus
medium).  (Cases of no or minimal sensitivity are covered by the minimal controls
specified in Section 3.)

For each application, determine the  relevant  security objective(s) and  sensitivity
level(s) based on the type of information the application/collection contains.  Note
that the time  value of  critical  information /applications  must  be  evaluated to
determine  sensitivity level,  and  the approximate  dollar value of  high  value
information /applications must be estimated to determine sensitivity level.  Most life
critical and mission  critical applications will probably involve high level sensitivity.
Most high value PC applications will probably involve medium level sensitivity.

It may be helpful to make notes about  security objectives and sensitivity levels in the
last three columns of the Table 4-1 worksheet.  A sample entry is provided.  In
instances where an application  turns out to  be at both the high and medium
sensitivity levels  vis-a-vis an objective,  the higher level dominates.  For example, an
application  that  contained  both National   Security  Information (high  level
confidentiality) and Privacy Act information (medium level confidentiality) would be of
high level confidentiality.
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Information Security Manual for PCs                                  12/15/89
                                  TABLE 4-2

              DETERMINING RELEVANT SECURITY OBJECTIVES
                        AND DEGREE OF SENSITIVITY
                                   Availability     Integrity      Confidentiality
                                  High  Med.   High   Med.    High   Med.
  Type of Information               Level Level   Level  Level   Level  Level

  •   National Security Information

  •   Critical to Performing a
     Primary Agency Mission
     -Must be Available Continu-
     ously or Within 1 Day           x             x
     -Must be Available
     Within 1-5 Days                        x       x

  •   Life Critical
     -Must be Available Continu-
     ously or Within 1 Day           x
     -Must be Available
     Within 1-5 Days                        x

  •   Financial Where Misuse
     Could Cause Loss                            x

  •   Automated Decision-
     Making Application                            x

  •   Subject to the Privacy Act

  •   Confidential
     Business Information

  •   Enforcement Confidential

  •   Budgetary Prior to
     OMB Release

  •   High Value
     -Very High Value*               x
     -Other High Value                      x

  •   Other"                                xx
  'While a precise set of criteria for distinguishing between "very high value" and "other high value"
  cannot be pro vided, the cost of replacing the information is the primary factor to consider. Clearly, an
  automated information system that cost $3.000,000 or more to develop and program would be of Ve/y
  high value."
  " Reader must determine which objectives are relevant based on characteristics of information/
  application.
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 By completing the Table 4-1 worksheet, a security profile is developed that includes
 information on types of  sensitive applications, security objectives, and sensitivity
 levels.  The security profile contains the basic information that owners need to
 completethe top of the Application Certification Worksheet. It also contains the basic
 information that  custodians need  to complete  the  top  of  the Risk Analysis
 Worksheet.

 4.3    DETERMINING THE PROCESSING ENVIRONMENT

 Several of the procedural controls specified in Sectibn 6-8 are described in terms of
 the environment in which the application or information is being processed. In using
 those  sections,  be alert  to  procedures that depend on  three  key environmental
 characteristics.    As a result, answer the following questions for  later use in
 implementing procedural controls.
     •   Is the PC a single user device or is  it shared among multiple users?
     •   Is the information/application stored on removable media (like a  floppy
        diskette) or non-removable media (like a fixed disk) or both (like a fixed disk
        with a floppy disk backup)?
     •   Does the  PC process  in isolation or does it communicate  with  other
        hardware? If it does communicate, which of the following communications
        configurations applies:
        -    Remotely Accessible by Modem (Dial-Up Capability)?
            PC to Resource Server?
            Local Area Network or LAN?

The security measures needed to maintain security in these different environments
will be described in later  sections. Regarding LANs, LAN System Administrators
must note that the National  Data Processing Division (NDPD) issues policies (for
example, governing access control or backup frequency) for Agency LANs. These
policies are contained in Section 310 of the "NDPD  Operational Policies Manual."
These  policies  are typically more  detailed and  technically  oriented  than the
procedures presented here.  LAN System Administrators must make sure that they
also comply with applicable NDPD policies.
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4.4   VALIDATING SENSITIVITY RESULTS

Determinations of sensitivity and degree of sensitivity must always be reviewed by
the cognizant supervisor.  Because implementing security safeguards can  involve
considerable expense and investment of staff time, management review of these
determinations is important.

Management review is also important because some of these determinations can
involve  an element of judgment and an organizational perspective is  important.
Critical or high value information is not as easily identified as Confidential Business
Information or P-ivacy Act data.   There may  be a tendency  for  individuals to
overdesignate their applications as  critical or  high value.  SIRMOs should  be
consjlted when employees and supervisors need guidance in making a sensitivity
deU.rmination.

4.5   USING THE .REST OF THIS MANUAL

The next section, Section 5, discusses personnel security.  This section needs to be
read by all EPA managers and staff who have sensitive applications or information.

Tne remainder of the manual, Sections 6-8,  is  organized by information security
objective:
        If availability is a security objective, review Section 6.
        If integrity is a security objective, review Section 7.
        If confidentiality is a security objective, review Section 8.
If more than one security objective is applicable (for example, an application where
both availability and confidentiality are relevant), make sure to read the section
pertaining to each applicable objective.

In discussing procedural controls, Sections 6-8 reference hardware and software
security products that are available under the PC contract.  Information on products
and prices was current as of December  1989.  Because the Agency periodically
updates contract offerings and prices, the reader should consult with his/her PC Site
Coordinator prior to placing an order.
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              5.  PERSONNEL SECURITY AND TRAINING
5.1   INTRODUCTION

Given the large number of PC Custodians and users in the Agency, PC security is as
much a people issue as it is a technical  issue. SIRMOs need to make sure that
cognizant supervisors in their organizations adhere to the following procedures.

5.2   SCREENING AND CLEARANCE

Federal  regulations require clearance  of all persons  involved in the design,
development, maintenance, and operation of sensitive  automated systems and
facilities.  These requirements apply to Federal employees and to the personnel of
agents (including contractors and grantees) of the EPA who have access to sensitive
EPA information.  Determinations of the degree of sensitivity of each position are
accomplished by the program offices.  The level of screening required should then
vary from minimal  checks to full background investigations,  depending upon the
sensitivity of the information to be handled by the individual in the position and the
potential  risk and magnitude of loss or harm that could be caused by the individual.
The responsibility for the implementation and oversight of the personnel clearance
program  rests with the Office of the Inspector General  (OIG) and the Personnel
Management Division, and EPA organizations should  consult with them  when
obtaining clearances or designating sensitive positions.

5.3   SEPARATION OF DUTIES

An individual has a harder time concealing errors and irregularities  if he/she does
not control  all aspects of an activity or transaction.  For example, by separating the
functions of cash handling and bookkeeping, the bookkeeper cannot get to the cash
and the cash register clerk cannot adjust the books to hide cash shortages.

Given the very definition  of personal computing, it is often  impractical to separate
duties. The same individual often collects data, programs the application, tests the
application, enters  data and generates the reports.  To minimize the potential for
fraud, abuse, or sabotage, however, these duties should be performed by separate
individuals to the maximum extent practicable.  When it is not possible to have each
duty performed by a  different  individual,  try  to separate the following: (1)  data
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information security Manual for PCs	12/15/89

collection /entry duties from application programming/maintenance duties, and (2)
application programming duties from application testing duties.

In the case of PC-based financial applications (relating to check issuance, funds
transfer,  and the like)  where misuse could cause loss, separation of  duties is
mandatory.  For example, the task of preparing  payment vouchers must be kept
separate from the task of approving payments. For such financial applications, other
preventive measures include periodically rotating jobs and asking people to take
vacations of one to two weeks.   Because the perpetrator of a fraud often has to
manipulate accounts on a daily basis to avoid detection, these measures may be a
strong deterrent.

5.4   TERMINATION/SEPARATION

In the event an employee has to be removed or laid off, it is a good idea to rotate the
employee to a non-sensitive position prior to  giving the employee notice of  the
action. While this may seem extreme, angry and demoralized employees have been
known to sabotage programs, erase data bases, or plant computer viruses.

Regardless of the type of separation (resignation, removal, etc.), supervisors need to
make sure the following are  performed for personnel separating from  sensitive
positions:
     °  Change or cancel all passwords, codes, user IDs, and locks associated with
       the separating individual.
     -  Collect all keys,  badges, and similar Kerns.
     °  Reconcile any financial accounts over which the employee had control.

The SIRMO  or his/her designate should then  certify that these procedures have
been accomplished by signing and dating a short statement that says: "Information
security procedures for  separating employee   (name)    have been completed.0
These statements should be kept on file for inspection by OIRM or the Office of the
Inspector General.

5.5   TRAINING

OIRM  is in  the process of coordinating the  development  of  a  comprehensive
information security training program for the Agency to supplement the procedures

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information security Manual for Pus	              12/15/89

in this manual.   Details and requirements of the program  will be issued under
separate  cover.    These  requirements  will include mandatory  basic  security
awareness training for every employee.  The program will include both information
security awareness training for  all  employees and training  in accepted security
practices  for those involved  in  the management, use,  or operation of sensitive
information. The program will identify and reference, as appropriate, existing training
in the information  security area, such as  training  done by the National  Data
Processing Division.
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Information Security Manual for PCs	12/15/89

           6.  MAINTAINING INFORMATION AVAILABILITY
6.1   INTRODUCTION
This section  sets forth  security procedures  for  owners,  users,  LAN System
Administrators,  and  custodians  of  applications  of high-level and  medium-level
availability (as determined in Section 4). This section is to be used as follows:
     -  Owners develop  the  security specifications  and the  tests needed for
       application certification based on the procedures presented here.
     -  Users make sure  they are in compliance with owner security specifications
       based on  these procedures.  In addition, users consul, these procedures
       when an owner has designated an application as sens\ive, but has not yet
       identified his/her security specifications.
     •  Custodians and LAN System Administrators  use these procedures to make
       sure that applications can be recovered in ihe event of a processing disaster
       and can be run elsewhere if necessary.  They also use these procedures to
       develop the information required for the risk analysis outlined in Appendix C.
The remainde, of  this  section  describes  threats,  safeguards,  and  recovery
procedures related to achieving the objective of maintaining availability. Subsection
6.2 catalogs and describes specific threats to information availability.  Subsections
6.3 and 6.4 specify security measures for medium availability  applications and high
availability applications, respectively.  The last subsection describes some steps that
can be taken to recover from a processing disaster.

6.2   THREATS TO APPLICATION AND INFORMATION AVAILABILITY
Specific threats to  data availability include:
     •  Theft
     •  Damage to magnetic media
     •  Hardware  failure: inability to restart
     -  Hardware  failure: failure during use
     •  Accidental data destruction or other operator  errors
     •  Sabotage  (deliberate data destruction)
     •  Failure of users to back-up data and programs.
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 Information Security Manual for PCs	      12/15/89

 The threats of theft and damage to magnetic media were addressed in Section 3.
 The remaining threats are described below.

 6.2.1  Hardware Failure: Inability To H^rt

 Because of the generally high reliability of microcomputers, users tend to become
 overconfident and do not protect themselves from system failures.

 In some cases, microcomputer systems are incapable of being restarted (booted)
 because of a hardware failure.
                                               V
 If the inab'irty to start the system is caused by a failure of the hard disk drive and it is
 necessary to  repair or replace the drive, the data on the  drive wfll probably be
 unavailable even after the system has been repaired.

 6.2.2  Hardware Failure: Failure During Use

 Although microcomputers do not often break down, the hardware can fail during use
 for a variety of reasons. The most common problem is a  disruption or surge of
 electric power, but the failure of almost any internal component can cause the
 system to crash.

 In addition to the problems that may be encountered if the system cannot be booted,
 failure during  use  will result in a disruption of ongoing processing.  If the system
 crashes while  in use, all data in the volatile, random access  memory (RAM) will be
 lost.   In addition,  if data files are open  at the time of the failure, they  may be
 corrupted.

 6.2.3  Accidental Data Destruction

 The most common way that data are accidentally destroyed is by users issuing
 incorrect commands.  For example, it is possible for users to destroy all of the data
 on  a  disk by inadvertently reformatting it.  This can be especially damaging if the
 hard disk is reformatted. Files can also be inadvertently deleted.  It is also possible
 to copy a file on top of an existing file if the name of the existing file is used as the
 destination of a copy command.

 Data can also  be accidentally destroyed by software malfunctions or incompatibility.
A particularly  serious potential problem is caused by an incompatibility  between
versions 2.x and 3.x of PC/MS DOS. Specifically, if a system containing a 20 mb or
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larger fixed disk formatted under version 3.x of DOS is booted from a diskette that
contains a 2.x operating system, the File Allocation Table of the hard disk will  be
damaged when data are written to the hard disk.  If this  happens, it might not  be
possible to access data stored on the hard disk.

6.2.4 Sabotage

Data can be deliberately destroyed by malicious  individuals, who may be either
authorized or unauthorized users.  Such destruction can be the result of vandalism
by those outside the office, but it can also be an act by an employee who has been
dismissed or disciplined, an act by a i individual who is hostile to the mission of an
office, or ?n act by an individual hostile to the implementation of a new computer
system. Fxamples include:
     •  An employee rnay oppose the implementation of performance monitoring
       software.
     •  An individual may use the data overwriting programs in PC utilities packages
       to erase files or disks.
     •  A dismissed employee may plant a "virus" in an organization's software prior
       to departure.
     •  An individual may feel that the automation of the individual's duties may
       make him or her more expendable.
     •  An individual  may believe that the implementation of a system intended to
       make his or her job easier will actually make his or her job  more difficult.

6.2.5 Failure to Backup Data and Programs

When  it comes to  regular and systematic backup, it unfortunately  seems that
experience is the best teacher. A user often needs to lose a key file before he/she
realizes the importance of regular backups. Failure to perform regular backups is
probably the most common and the most serious threat to availability.
6.3   PROCEDURES TO MAINTAIN MEDIUM-LEVEL AVAILABILITY

This subsection applies to applications that can be unavailable for a period of only
one-to-five days and/or applications that are of "other high value."
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 6.3.1  Lock-up Media

 To avoid theft, store media in a locked cabinet or room.

 6.3.2  Write Protection

 Whenever possible, wrrte-protect files and programs to avoid accidental destruction.

 6.3.3  Isolated Storage

 Isolate the critical/high value application on its own storage  media to the extent
 possible.  For an application residing on a floppy diskette, this means dedicating the
diskette to the one sensitive application.  For an application residing on a fixed disk,
this could mean dedicating a separate subdirectory or partition to the software.
Such isolation speeds the backup process (discussed below).

6.3.4  Backups

In general, the most important step to be taken to protect information availability is to
implement a  regular schedule of backups.  Backups are performed to provide for
easy recovery from a disaster.  If information has been backed up, and if the backup
is safely stored, the information will be recoverable - no matter what happens.  Note,
however, that transactions that have occurred since the last backup may have  been
lost and may  need to be re-input.

DATA BACKUPS

Each PC user needs to establish a backup loop to protect his/her  data and  files.
The backup loop is a systematic way of creating multiple generations of copies. The
frequency and number of backup generations made and stored should be a direct
function of the value of the information and the cost of regenerating it. In general, two
to five generations are recommended.   Two  examples involving diskettes are
provided below:
     •  A two-generation scheme for a floppy disk would be performed as follows:
          -   On the first day, the data on the original diskette would be copied to
             Diskette 1.
          -  On the second day, the data on the original diskette would be copied
            to Diskette 2.
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          - On the third day, the data would be copied to Diskette 1, writing over
            the backup from the first day.
     •  A five-generation  scheme for a fixed disk system would  be  performed as
       follows:
          - On Monday of the first week, the data on the  fixed disk would be
            copied to a set of diskettes designated as Set 1.
          - On Tuesday, the data could be copied to Set 2. Wednesday's backup
            would be copied to Set 3, Thursday's to Set 4, and Friday's to Set 5.
          - On Monday of the second week, the  data would be copied to Set 1,
            writing over the Monday backup irom the previous week.

Under a five-generation scheme, *he  user has a significant level of protection. Even
if the original data and one or tv o of the backups were  destroyed, only one or two
days of work would be lost.

The backup loop does not have to involve diskettes.  As discussed below, tape
backup systems or  Bernoulli boxes  can be more efficient.  Moreover, if the PC is
connected to a LAN file server or remote host (such as a mainframe computer), the
remote device  may provide backup protection.   Consult the manager of the remote
facility or the LAN System Administrator for information.

Backup copies stored  in the general vicinity of the original  data protect against
problems such as a system crash or an accidental erasure of data.  They do  not.
however, protect against a threat such as a fire which could affect an entire floor or
building. As a result, each month a copy should be  taken out of the backup loop
and stored in a physically separate location. This archival copy would probably not
be completely  current in the event of a major disaster, but it would have great data
recovery utility. To prevent archival copies from piling up, the copy that has been in
archives should replace the one taken out of the backup loop. There may also be
advantages in  retaining several generations of the archival copies.

For Headquarters employees, the WIC is recommended as an  off-site location.  The
WIC does charge a fee for  storing backup copies, and participating organizations
execute an Operational Service Agreement for Archiving of PC Software  with the
WIC. If the PC is connected to a remote host or file  server, it may be possible to use
the remote device as the off-site location.  Consult the manager of the remote facility
or the LAN System Administrator for assistance.
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When files get large, users are tempted to employ the incremental backup approach.
An incremental  backup focuses only on what has been changed and includes only
those files  that have been modified since the last backup.  The advantage of an
incremental backup is that it can be performed faster than the full backups discussed
above.  The disadvantage of incremental  backups is that no single  backup will
contain all  of the files and data.  If the original files are destroyed or lost,  it will be
necessary to reconstruct the  data from the most recent full backup and all of the
incremental backups  that have been  performed since.   In addition  to  being
inconvenient, this process of reconstructing the files is risky. If the last full backup or
any of the incremental backups has anything wrong with it, it may be impossible to
perform a fully successful recovery.

Because of these difficulties, incremental backups are not recommended. Instead, if
the data files are so large that the backup process fills  about 15 diskettes, consider
using a streaming tape backup system or a Bernoulli Box. A streaming tape backup
system is available  under the PC contract for about $500.  The Bernoulli Box, which
is available for about $800 (10 megabyte) or about  $1200 (20 megabyte) under the
PC contract, makes backups straightforward and  quick.   It also provides certain
access  controls, for  example, partitioning  software.   If the PC  is also used for
confidential  processing, the  box becomes more  cost effective.   In  addition,  if
software as well as data are  stored on Bernoulli disks, and a second PC with a
Bernoulli Box is  available, each PC can be a backup  facility for the other.

SOFTWARE BACKUPS

Backups should not be  limited to data and files.  End user applications (software
developed or maintained locally) should also be backed up and stored at the off-site
storage facility. Source program files, loadable versions of all software, and  required
compiler or interpreter programs should be included.

6.3.5  Continuity of Operations

Backup computing facilities  must  be identified for  critical  applications  and an
agreement  for use  of the backup facility shall be executed. The agreement for the
backup facility should  not be an informal and vague oral agreement,  but instead
must involve a memorandum  between the PC custodians identifying all conditions
(for example, the amount of machine time to be made available).
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6.4   PROCEDURES TO MAINTAIN HIGH-LEVEL AVAILABILITY

This subsection applies to applications that must be available continuously or within
one day, and/or applications that are of very high value. All of the procedures set
forth in Section 6.3 also apply here. The  following additional procedures will be

followed to maintain high-level availability.

6.4.1 Uninterruptible Power


Obtain an Uninterruptible Power Supply (UPS) device to provide virtually complete
surge protection, a filter for line noise, and power in the event of an outage. A UPS is
                                               V
available for approximately $1100 under the PC contract.

6.4.2 Manual Fallback

Identify and formalize manual data processing procedures to be followed  in the
event of a complete disaster in which the application is made unavailable.


6.4.3 More Frequent Backups

Consider preparing full backups for off-site storage on a weekly or even daily basis.


6.5   SUGGESTIONS FOR RECOVERING FROM A DISASTER

'n the event of a problem or disaster, it is often best to stop using the PC and seek

help from the PC Site Coordinator. The following may then help restore availability:

     •   It may be possible to recover data stored on the undamaged portions of the
        damaged medium using the DOS DEBUG facility or some other hexadecimal
        editor.  This will be a  difficult  task and should only be undertaken  by
        individuals  with a thorough understanding of their systems.

     •   Commercially available utility packages (such as the Norton Utilities package
        available under the PC contract for about $100) can help in recovering data
        and in unformatting an accidentally formatted disk.

     •   If backups have been made, data and software that is not copy-protected
        can be restored from the backups.  Contact the  manufacturers of copy-
        protected  software to  investigate  their policy for  replacing  damaged
        software.

     -   If summary data have been  damaged, but detailed records  or other audit
        trails  were  undamaged,  it may be possible to recreate the summary data
        from  the detailed records.   In some cases it  might even be possible to
        recreate detailed records if sufficient audit trail information is available.
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              7.  PRESERVING INFORMATION INTEGRITY

 7.1    INTRODUCTION

 This  section  sets  forth security  procedures for  owners, users, LAN System
 Administrators,  and custodians of applications  of high-level  and medium-level
 integrity (as determined in Section 4). This section is to be used as follows:
     •  Owners develop the  security  specifications and  the  tests  needed for
        application certification based on the procedures presented here.
              make sure they are in compliance with owner security specifications
        based  on  these  procedures.   In addition,  users  may consult  these
        procedures when an owner has designated an application as sensitive, but
        has not yet identified his/her security specifications.
     •   Custodians and  LAN System  Administrators  use these  procedures to
        determine what security measures must be in place at his/her installation to
        maintain integrity.   They  also  use these  procedures  to develop  the
        information required for the risk analysis outlined in Appendix C.

The remainder of this section discusses threats to integrity and procedures to
safeguard  and  recover  system integrity.   The next  subsection catalogs  and
describes specific threats to information integrity.  Subsections 7.3 and 7.4 specify
security measures for applications of medium-level integrity and high-level integrity,
respectively.  The last subsection describes some steps that can be taken to recover
from data corruption.
7.2   THREATS TO INTEGRITY

7.2.1  Deliberate Distortion of Information:  Fraud and Sabotage

Data integrity can be damaged by the deliberate actions of system users or other
individuals with access to the system.  Such damage could take the form of a virus.
These actions could be motivated by revenge (for example, by recently disciplined or
reprimanded employees) or could be intended to perpetrate or cover up fraudulent
activities, mismanagement, or waste.

Fraudulent activities include embezzlement or any other deception intended to cause
the deprivation of property or some  lawful right. Fraud could be intended to prevent
or influence enforcement actions or other operations of the Agency.
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7.2.2 Accidental Damage

Accidental  damage to data  integrity results when individuals  inadvertently and
unknowingly modify data, erase files, input incorrect data, or introduce program
bugs.

Accidental  threats  to data integrity overlap with the issues discussed under data
availability. The distinction is based on whether the data distortion is discovered.  If
so, the  distortion would generally be considered to consist of a loss of data and
would,  therefore, represent an availability  problem. When the damage remains
undetected, decisions may be made or other actions may be taken based upon
incorrect information, resulting in a failure of data integrity.

7.2.3 Other Considerations

In addition to the  above, information integrity can also  be affected by flaws in
software applications design and development (for example, incorrect algorithms or
mathematical formulae). A review of all of the system design issues that are relevant
to data  integrity is beyond the scope of this manual.  Instead, the reader is referred
to the three volume set of "EPA System Design and Development Guidance" issued
by OIRM.  This comprehensive set of standards includes  references to security at
appropriate points  in the  software design/development process.  For more explicit
guidance on designing security into applications, the reader is also referred to
Federal  Information  Processing Standard (FIPS) PUB 73 and to the  Agency's
"Information Security Manual."  FIPS PUB 73 is available in the  Headquarters library
or through the National Technical Information Service (NTIS).

This manual will limit itself to a consideration of threats to data integrity involving
deliberate and accidental  actions of users and involving other events that can occur
during system use.

7.3   PROCEDURES TO MAINTAIN MEDIUM-LEVEL INTEGRITY

The  security  measures  needed to  ensure integrity  represent a mix  of those
associated with maintaining  availability  and those  associated with preserving
confidentiality. Availability and confidentiality are almost opposftes; backup copies of
a data base made  to enhance availability can aggravate the problem of preventing
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the  disclosure of data stored in the data base.  In a very real sense, however,
integrity is the objective in the middle.

Integrity involves elements of the availability objective because if data are corrupted
or partially  destroyed, intact  backup  copies are essential.  On the other hand,
integrity involves elements of the confidentiality objective because preventing fraud
and sabotage are largely problems of controlling access.

7.3.1  Availability-Related Procedures

Adhere to all of the procedures described in Section 6.3, with the exception of those
associated with continuity of operations. This wfll ensure that backups are created.

7.3.2  Confidentiality-Related Procedures

Adhere to the access  control procedures described in Sections 8.3.2  and 8.3.3.
Also, follow the  password management  practices outlined  in Section  8.3.1.  In
addition, for PCs in a LAN, adhere to the procedures outlined in the following three
paragraphs.

In a LAN, all  points can  read traffic on the network.  In addition, all points have
access to common storage media. Indeed, the ability to share printers  or storage
(file servers) is often a key reason why networks are created.

The  LAN System Administrator is responsible for  coordinating the selection of
security safeguards  for  the   network to ensure  overall  effectiveness.   LANs
sometimes have security packages available as part of their operating systems.
These may be considered in selecting safeguards for the network.

If all  network users have access  to  all  information processed on the network,
establish a formal list of those authorized users (an administrative control).  To the
extent possible,  bolster this administrative control by  keeping  each PC on the
network under lock and key when not in use.  Require users to provide a password
when logging on to the network.

7.3.3 Audit Trails and User Accountability Tracking

If fraud and  sabotage  are threats, audit trails  and operator tracking  should be
incorporated  into the application software.  The software should be designed to
automatically insert the operator identifiers into each record based upon a password

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supplied during the system sign-on process. Data integrity and user accountability
would be further enhanced if the application software and data base were compiled

and encrypted to prevent the password mechanism from being bypassed.



7.4   PROCEDURES TO MAINTAIN HIGH-LEVEL INTEGRITY


All  of the procedures set forth  in Section  7.3 also  apply here.  In  addition, the

procedures listed below will be followed.


7.4.1  Uninterruptible Power


Obtain an Uninterruptible Power Supply (UPS) device to provide virtually complete

surge protection, a filter for line noise, and power in the event of an outage. A UPS is

available for about $1100 under the PC contract.


7.4.2  Manual Fallback


Identify and formalize manual procedures to be followed in the event of a complete
disaster.


7.4.3  More Frequent Backups


Consider preparing backups for off-site storage on a weekly or even daily basis.



7.5   SUGGESTIONS FOR RECOVERING FROM A DISASTER


In the event of a problem or disaster it is often best to stop using the machine and

seek help from the PC Site Coordinator.  The  following may then help restore

integrity:

    •  It may be possible to recover data stored on the undamaged portions of the
       damaged medium using the DOS DEBUG facility or some other hexadecimal
       editor.  This will be a difficult task and  should  only be undertaken by
       individuals with a thorough understanding of their systems.

    -  Commercially available utility packages (such as the Norton Utilities package
       available under the PC contract for about $100) can help in recovering data
       and in unformatting an accidentally formatted disk.

    -  If backups have been made, data and software that is not copy-protected
       can be  restored from the backups.  Contact the manufacturers of copy-
       protected  software  to   investigate  their  policy  for replacing  damaged
       software.


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     •  If summary data have been damaged, but detailed records or other audit
       trails were undamaged, it may be possible to recreate the summary data
       from the detailed records.  In some cases it might even  be possible to
       recreate detailed records if sufficient audit trail information is available.
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         8.  PRESERVING INFORMATION CONFIDENTIALITY

8.1   INTRODUCTION


This section  sets forth  security procedures  for owners,  users,  LAN  System
Administrators,  and custodians of confidential applications and information.  This
section is to be used as follows:

     •  Owners develop  the  security specifications  and the  tests needed for
       application certification based on the procedures presented here.
             make sure they are in compliance with owner security specifications
       based  on  these  procedures.   In  addition, users may  consult  these
       procedures when an owner has designated an ar/plication as sensitive, but
       has not yet identified his/her security specifications.

    •  Custodians use these  procedures to  determine what  security measures
       must be  in place to protect the confidential information being stored and
       processed by users of his/her installation.  They also use these procedures
       to develop the information required for the risk analysis outlined in Appendix
       C.

    •  LAN System Administrators must note (per Section 8.3.3) that no confidential
       data may be loaded on to a LAN or made available via a LAN unless
       specifically approved in writing by the Director of OIRM.


The remainder of this section discusses threats to  information confidentiality and

procedures for safeguarding against disclosure. The next subsection catalogs and
describes specific threats to confidentiality. Subsections 8.3 and 8.4 specify security

measures  for  applications of  medium  level  confidentiality  and  high level

confidentiality, respectively.  Features of the processing environment are particularly

important for preserving confidentiality, and are discussed in those subsections as
appropriate.


Unlike Sections 6 and 7, there is no separate  discussion here of steps to recover

from a breach of confidentiality.  Once information has been disclosed, there is little

the individual can do to remedy the situation.  Instead, the breach must be reported

to appropriate Agency officials, as described in the Information Security Policy.
8.2   THREATS TO APPLICATION AND INFORMATION CONFIDENTIALITY


Specific threats to information confidentiality are largely problems of access control

Note that the threats described below apply to confidential information in its various
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forms, that is, in the computer, in hard copy, on removable media like diskettes, and
on printer ribbons.

     •   Magnetic  media containing confidential data can be accessed by individuals
        from whom the data should be restricted. If the computer is not in a secure
        area, intruders can start the system containing the information and browse
        information on the fixed disk.  If diskettes containing confidential information
        are not secured,  unauthorized individuals can install them on a computer
        and browse their contents.

     -   Unauthorized individuals can see data on a computer screen or printout if
        confidential data are processed in an unsecured area or if printouts are not
        protected in storage.

     •   Confidential data can be deciphered from printer ribbons that have  been
        used to print confidential reports.

     •   Unauthorized individuals can  access confidential data across a local area
        network or other  communications device if confidential data are stored or
        processed on a microcomputer that can be accessed remotely.

     •   Files erased  from a magnetic disk  using only the standard DOS "DEL" or
        "ERASE" commands  are not actually erased from the computer disk-they
        are only marked  for  deletion, and the space on which they are written is
        freed for use  by later files.  For this reason, until they have been overwritten,
        they can be "unerased" using commercially available utility programs.

     •   Some software systems use work files that are temporarily stored on disk.
        Although the  systems usually delete these files when they are finished with
        them, the  deleted files may be recoverable  using commercially available
        utility programs.  Similarly,  information could be (eft in the volatile (RAM)
        memory of the computer if the computer is not turned off after confidential
        data have been processed.

     -   Individuals authorized to access confidential information could deliberately
        share printed reports  or magnetic media containing confidential  data with
        unauthorized individuals.
8.3   PROCEDURES TO PRESERVE MEDIUM-LEVEL CONFIDENTIALITY


Preserving confidentiality involves controlling access to information and applications.

How easy or difficult it is to control access is highly dependent  on the three key

environmental characteristics  (single  user versus  shared,  stand-alone  versus

communicating, removable  versus non-removable media).  The simplest situation

consists of a single user who does stand-alone processing and stores all confidential

information on  floppy  disks.   When the  PC is  shared or in a communicating
configuration, the security situation becomes more complicated.
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The procedures that follow are  presented largely  in  terms  of processing

environment.    Following a short subsection  on  controls that  apply  to  all

environments, more complicated environments are discussed.  The security controls
required fall into the following categories:

     •   Physical, such as door locks

     •   Administrative, such as lists which specify who is allowed access to a given
        PC

     •   System-Based, such as password protection

     •   Information-Based, that is, rendering information unusable  (even  if it is
        obtained) through scrambling or encryption techniques.   As an example,
        some commercial software (for example, Lotus 1-2-3 version 2) contain data
        encryption capabilities. The Lotus 1-2-3 data encryption cafabDity enables
        users  to password-protect their Lotus  spreadsheets.   The encrypted
        spreadsheets cannot be accessed without the assigned password and date;
        in them are encoded to prevent the data files from being read through DOS
        functions o- other utilities.

It should be noted that EPA organizations with statutory authority for certain types of
confidential information may issue security  procedures dealing exclusively with a

particular type of information (for example, TSCA, or  FIFRA CBI).  Because of

statutory requirements, some of those procedures may be more stringent than those

required here. EPA employees must make sure that they also adhere to all pertinent
organizational standards and procedures.


8.3.1  Procedures for all Environments

     •   Discourage traffic in the area where the computer is located when it is in use.
        Unauthorized individuals should be kept out of the area so that they cannot
        view data that might appear on the computer screen.

     •   Log off or otherwise inactivate the PC whenever leaving it.

     •   Store hard-copy reports and removable media containing confidential data in
        locked cabinets or rooms.

     •   Printer ribbons  used to  print   confidential data should  be considered
        confidential as well.   Destroy exhausted  ribbons so  that they cannot be
        deciphered by an unauthorized individual.

     •   Be  careful when  disposing  of  disks, diskettes, or  tapes that  contain
        confidential data.   Before these media are thrown away  or  recycled, they
        must be  degaussed, overwritten, or shredded.  (Degaussing erases data
        through demagnetization.) The WIPEDISK program in the Norton Utilities
        package  (available under the PC  contract for about $100) destroys all data
        on the disk by overwriting them.


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     -  When erasing individual files on diskettes or fixed disks, use an overwriting
        program like WIPEFILE in the Norton Utilities package.  These overwriting
        programs are effective. Be careful not to erase needed files.

     •  (It should be noted that programs designed to purge and overwrite individual
        files (like WIPEFILE) may only overwrite the most recent generation of a file.
        This  would  also  destroy previous  generations  of the file  if they were
        physically located in the same disk addresses as the last generation of the
        file.  If the previous generations were located elsewhere on the disk, or if the
        last  generation file is  smaller than the previous generations, the previous
        generations may not  be entirely  overwritten by the file destruction utility.
        Recovery of these undestroyea  fragments, however, would  be extremely
        difficult and tedious for even  the most knowledgeable intruder, and it is
        unlikely that more than small fragments of the sensitive information could be
        recovered.)

     •  If passwords are selected as a control measure (based on the procedural
        guidance below), make sure passwords are selected and  handled as
        follows:

          -  Passwords are at least six characters long

          -  Passwords contain at least one alpha and one numeric character

          -  Passwords  are not composed of names or similar personal types of
             information

          -  Passwords are not shared

          -  Passwords are changed at least quarterly

          -  Passwords are not written out and left where an unauthorized person
             could find them

          -  Passwords are not incorporated into automated logon procedures in
             batch files or application programs (for example, Crosstalk), and they
             are not defined under function keys.

        Passwords  can  either   be  incorporated into  applications  systems  or
        implemented through  add-on circuit boards.  While application-based
        password schemes may prevent casual intruders, they usually  do not
        prevent the knowledgeable  intruder  unless special steps are taken (for
        example, encryption).  Knowledgeable intruders may be able to avoid the
        passwords altogether or may scan  application listings to determine the
        password.    For  this reason, the   more sophisticated  hardware-based
        password schemes are recommended.  Cylock, available under the PC
        contract for about $300, is hardware based.


8.3.2 Procedures for Stand-Alone Processing


This part applies to PCs that process in isolation and do not communicate with any
other equipment.
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CONFIDENTIAL DATA ON REMOVABLE MEDIA ONLY; SINGLE USER OR SHARED
USER PC

Clear the  system of confidential  information after each  confidential processing
session.  Power off the unit to clear any volatile memory, that is, random access
memory.

CONFIDENTIAL DATA ON NON-REMOVABLE MEDIA; SINGLE OR SHARED USER
PC

Keep the computer under lock and key when it is not being used, that is, keep it in a
locked cabinet and/or a locked room.

If all users of a shared PC have access to all information processed on the PC,
establish a formal list of those authorizod users (an  administrative control).  Limit
access to those  on this authorized list.  If this is not the case, users must be
protected from each other via either a password scheme or encryption. Encryption
software (Datasafe) is available under the PC contract to. under $100.

8.3.3 Procedures for Communicating PCs

This section  applies to PCs that  are connected to other equipment such as
autoanswer modems, other PCs, or resource servers.

AUTOANSWER MODEM; SINGLE USER OR SHARED PC

PCs are sometimes used as host systems. An autoanswer modem allows a person
to use the system remotely. Keep the computer under lock and key when it is not in
use, that is, keep it in a locked room or a locked cabinet. Use a password scheme
that requires both a traditional user identifier and a password logon process. Under
no circumstances should users share passwords.

TERMINAL EMULATION

At times, a PC is used as a terminal device to a large host system.  In this situation,
security controls are the responsibility of the host system.  The host should control
access and the extent to which data are sent (uploaded) or received (downloaded).
The  PC user  needs to make sure he/she  adheres to all host-imposed security
requirements.  In addition, the PC must never store host telephone numbers, logon
sequences, or passwords in the PC itself.

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LOCAL AREA NETWORKS; SINGLE USER OR SHARED PC

No confidential data may be loaded on to a LAN or made available via a LAN unless
specifically approved in writing by the Director of OIRM.

8.4   PROCEDURES TO PRESERVE HIGH-LEVEL CONFIDENTIALITY

The EPA has only one type of information in this category - National Security
Information (NSI). The amount of NSI possessed by the Agency is extremely small,
and the need to computerize any of it would be very infrequent.

Because of the small quantity of NSI in the Agency and because NSI involves special
security considerations  (emanations  security and  TEMPEST devices),  NSI should
not be placed on PCs without the express approval of the Director, OIRM.
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                              APPENDIX A
                       INFORMATION SECURITY*

1.    PURPOSE.   This  document  establishes  a comprehensive,  Agency-wide
security program to safeguard Agency information resources. This document sets
forth the Agency's information security  policy for both manual and  automated
systems and assigns individual and organizational responsibilities for implementing
and administering the program.

2.    SCOPE  AND  APPLICABILITY.    This  dbpument  applies  to all  EPA
organizations and their employees. It also applies to the facilities and personnel of
agents  (including  contractors and grantees)  or  the  EPA  who  are involved in
designing, developing, operating or maintaining Agency information and information
systems.

3.    BACKGROUND

      a.    Information is an Agency asset, just as property, funds and personnel
            are Agency assets. The EPA is highly dependent upon its information
            resources to carry out program and administrative functions in a timely,
            efficient and accountable manner.

      b.    The EPA relies on its information collection authority under  various
            enabling  statutes to fulfill effectively  its environmental missions. The
            willingness of the regulated community and State and local agencies to
            supply requested information in  a cooperative and timely  fashion
            depends on their confidence that the information will be adequately
            protected.

      c.    The Agency's information resources are exposed to potential loss and
            misuse from  a variety  of accidental and deliberate  causes.  This
            potential loss and misuse can take the form of destruction, disclosure,
            alteration, delay or undesired manipulation. Moreover, the Agency can
            be subject to acute embarrassment and litigation if certain business or
            personal information is inadvertently or maliciously disclosed.
'Source: EPA Information Resources Management Policy Manual, Chapter 8.
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      d.     As a result, it is  essential that an overall program be established to
             preserve and adequately protect the Agency's information resources.
             At the  same  time,  it is  equally  essential  that  the  program  not
             unnecessarily restrict information sharing with other Federal agencies,
             universities, the public and State  and local environmental  authorities.
             Such  information  sharing has historically played a  vital  role in  the
             overall fulfillment of the Agency environmental mission.

      e.     The management, control and responsibility for information resources
             within EPA are decentralized.  Consequently, the management and
             responsibility for  information  security are also decentralized.   An
             important example of this is the expanding use of personal computers,
             networking, distributed data bases and telecommunications.  These
             trends  place  new  responsibilities  on  office  managers,  research
             personnel   and   others  not  previously  considered   information
             processing professionals.  The "computer center" cannot be  relied
             upon to protect Agency operations.  Controls must  be implemented
             and maintained where they are most effective.

      f.      In determining  responsibilities for information security,  it is  useful to
             define a framework of owner/custodian/user. Owners are those who
             create or maintain information. Custodians are typically suppliers of
             information services who possess, store, process and transmit  the
             information. These roles are often not discrete; the owner  is often  the
             principal custodian and user of the information.

4.    AUTHORITIES

      a.     OMB Circular A-130, Management of Federal Information Resources.

5.    POLICY.  It  is EPA policy to protect adequately sensitive  information and
sensitive applications, maintained in any medium (e.g., paper, computerized data
bases, etc.), from  improper use, alteration or disclosure, whether accidental or
deliberate.  Information and applications wDI be protected to the extent required by
applicable law and  regulation in accordance with the  degree of their sensitivity in
order to ensure the cost-effectiveness of the security program.
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       a.     Information security measures will be applied judiciously to ensure that
             automated systems operate effectively and accurately and to ensure
             the  continuity of operation of automated information systems and
             facilities that support critical agency functions.

       b.     As required by OMB Circular No. A-130, all automated installations will
             undergo a periodic risk analysis to ensure that appropriate, cost-
             effective safeguards are in place.  This risk analysis will be conducted
             on new installations, on existing installations undergoing  significant
             change and on existing installations at least every five years.
                                                t •-
       c.     Appropriate administrative, physical, and technical safeguards shall be
             incorporated into all new ADP application systems (including PC-based
             applications)  and major modifications to existing systems.

       d.     As required by OMB A-130, all new applications will undergo a control
             review leading to formal certification.  Existing sensitive applications will
             be recertified every three years.

       e.     Access  to   sensitive   personnel  information   and   employment
             applications will be limited to appropriate personnel in accordance with
             procedures established by the Office of Personnel Management and
             monitored  by the EPA Office of the Inspector General.

       f.      Appropriate  ADP  security  requirements  will be incorporated into
             specifications for the acquisition of ADP related services and  products.

       g.     An  information  security awareness  and training program will  be
             established so that all Agency and contractor personnel are aware of
             their information security responsibilities.

       h.     Information security must be a major factor in evaluating the  use of
             microcomputers.    Microcomputer  systems software  is typically
             rudimentary  and affords little or  no protection  to  information and
             programs.   Consequently,  networked  microcomputers, the ability to
             download data from larger, protected computers onto microcomputers
             and microcomputer data processing generally present  problems in
             information security (for example, problems of  access control  or
             control over the dissemination of information). All EPA employees and

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             managers must be aware of the information security implications of
             storing and processing sensitive information  on  microcomputers,
             whether networked or stand-alone.

      i.      Therefore, it is EPA policy to discourage the use of microcomputers for
             storing or processing sensitive information, unless cognizant  EPA
             employees and managers have made sure that adequate information
             security measures are in use. If adequate information security cannot
             be maintained, an alternative system configuration must be used.

      j.      Information security violations wOl be promptly reported to appropriate
             officials, including the Inspector General.


6.     RESPONSIBILITIES

      a.     The Office of Information Resources Management is responsible for:

            (1)    Developing  and  issuing  an  information  security  policy  in
                   accordance with  all applicable Federal laws,  regulations, and
                   executive orders.

            (2)    Ensuring that all Agency organizational units are in compliance
                   with the information security program.

            (3)    Establishing training criteria and coordinating the development
                   of an information security training and awareness program.

            (4)    Providing guidance on selecting and implementing safeguards.

            (5)    Participating as it deems appropriate,  in management  and
                   internal  control reviews conducted  by the  Office of  the
                  Comptroller to ensure compliance with the information security
                  program.

      b.     Each "Primary Organization Head" (defined by EPA Order 1000.24 as
            the  Deputy  Administrator,   Assistant  Administrators,  Regional
            Administrators, the Inspector  General and the General Counsel)  is
            responsible for:
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             (1)    Ensuring that sensitive information and applications within the
                   organization are adequately protected.

             (2)    Establishing  an  organization-wide program  for  information
                   security consistent with organizational  mission and Agency
                   policy, including assigning responsibiity for the security of each
                   installation  to a  management  official(s)  knowledgeable  in
                   information technology and security.

             (3)    Assure annually  the Assistant Administrator for Administration
                   and  Resources  Management that organizational  information
                   resources are adequately protected. This will be done as part of
                   the internal control  review process required under OMB Circular
                   No.  A-123  (revised)  and  implemented  under  EPA  Order
                   1000.24.

             (4)    Making  sure  that all   automated  installations  within  the
                   organization undergo  a  periodic "risk analysis" to ensure that
                   appropriate, cost-effective safeguards are in place.

             (5)    Ensuring the continuity of operations of automated information
                   systems and facilities that support critical functions.

             (6)    Making sure that appropriate safeguards are incorporated into
                   all  new  organizational  application  systems   and  major
                   modifications to  existing systems, that all new organizational
                   applications undergo an information security review leading  to
                   formal certification  and that existing sensitive applications are
                   recertified every three years.

             (7)    Making sure that Federal employees and contractor personnel
                   understand their security responsibilities and that organizational
                   security regulations are properly distributed.

             (8)    Making  sure that  all  organizational  procurements  of  ADP
                   equipment, software and services incorporate adequate security
                   provisions.
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       c.     The  Director,  Facilities  Management  and  Services  Division,  is
             responsible for:

             (1)    Establishing and  implementing  physical  security standards,
                   guidelines and procedures in accordance with EPA information
                   security policy.

             (2)    Establishing and implementing standards and procedures for
                   National  Security   Information  in  accordance  with   EPA
                   information  security  policy and  all applicable  Federal  laws,
                   regulations and executive orders:

      d.     The Procurement and Contracts Management Division and the Grants
             Administration Division are responsible for:

             (1)    Ensuring that Agency grant and contract policies, solicitations
                   and  award  documents  contain  provisions  concerning the
                   information security responsibDities of contractors and grantees
                   that have been promulgated by OIRM.

             (2)    Establishing  procedures  to  ensure  that  contractors  and
                   grantees are  in compliance  with their  information security
                   responsibilities.  Project Officers  are responsible for ensuring
                   contractor compliance with security requirements on individual
                   contracts. Violations shall be reported to the contracting officer,
                   Inspector General  and  appropriate OIRM official.   Specific
                   violations involving  National  Security  Information  shall  be
                   reported to the Director,  FMSD and the Contracting Officer.

      e.     The Office of the Inspector General is responsible for:

            (1)    Establishing and implementing personnel security  standards,
                   guidelines and  procedures in accordance with EPA information
                   security policy and all applicable Federal laws and regulations.

            (2)    Conducting  or arranging investigations of known or suspected
                   personnel security violations as it deems appropriate.
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      f.      The Office of the Comptroller is responsible for:

             (1)    Allowing OIRM to review written internal control reports so that
                   OIRM is aware of the status of information security weaknesses.

      g.     Each EPA Manager and Supervisor is responsible for:

             (1)    Making  sure their  employees are  knowledgeable of their
                   information security responsibilities.

             (2)    Ensuring  that  their  employees adhere  to  the  organizational
                   information security program  established  by the  applicable
                   Primary Organization -Head.

      h.     Each EPA Employee, Cor/tractor and Grantee is responsible for:

             (1)    Complying fully with his/her information security responsibilities.

             (2)    Limiting his/her access only to information and systems he/she
                   is authorized to see and use.

             (3)    Adhering  to all Agency and organizational information security
                   policies, standards and procedures.

             (4)    Reporting information security violations to appropriate officials.
                   Violations involving National Security  Information shall also be
                   reported to the Director, FMSD.
7.     DEFINITIONS.

       a.     "Applications Security"  means the set of controls  that  makes an
             information system perform in an accurate and reliable manner, only
             those  functions it was designed  to  perform.   The set of controls
             includes the following:  programming, access, source document, input
             data, processing storage, output and audit trail.

       b.     "Confidential Business Information" includes trade secrets, proprietary,
             commercial/financial information, and other information that is afforded
             protection from disclosure under certain circumstances as described in
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             statutes administered by the Agency. Business information is entitled
             to confidential treatment if: (1) business asserts a confidentiality claim,
             (2)  business shows  it has taken its own measures to protect the
             information, (3) the  information is not  publicly available  or (4)
             disclosure is noj required by statute and the disclosure would either
             cause  competitive harm or impair the Agency's ability  to  obtain
             necessary information in the future.

      c.     "Information" means  any communication or reception of knowledge
             such as facts,  data or  opinions,  including numerical,  graphic,  or
             narrative forms, whether oral or maintained in any medium, including
             computerized data bases (e.g., floppy  disk and  hard disk), papers,
             microform (microfiche or microfilm), or magnetic tape.

      d.     "Information Security" encompasses three different "types" of security:
             applications security,  installation security and personnel security.  In
             total, information security involves the precautions taken to protect the
             confidentiality, integrity and availability of information.

      e.     "Information System" means the organized collection,  processing,
             transmission and  dissemination  of  information  in accordance with
             defined procedures, whether automated or manual.

      f.      "Installation" means the physical location of one or more information
             systems, whether  automated or  manual. An automated installation
             consists of  one or  more computer or office  automation  systems
             including related peripheral and storage units, central processing units,
             telecommunications  and  operating  and support system  software.
            Automated  installations may range in  size  from  large centralized
             computer centers to stand-alone personal computers.

      g.    "Installation Security"  includes the use of locks, badges and similar
             measures  to control  access to  the installation  and  the measures
            required for the protection of the structure housing the installation from
            accident, fire and  environmental  hazards.  In addition to the above
            physical security measures, installation security also involves ensuring
            continuity of operations through disaster planning.
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       h.     "National Security Information" means information that is classified as
             Top Secret, Secret, or Confidential under Executive Order 12356 or
             predecessor orders.

       i.      "Personnel Security" involves making a determination of an applicant's
             or employee's loyalty and trustworthiness by ensuring that personnel
             investigations are completed commensurate with  position sensitivity
             definitions according to the degree and  level  of access to  sensitive
             information.

       j.      "Privacy" is the  right of an individual to control the collection, storage
             and dissemination of  information about  himself/herself to avoid the
             potential for  substantial  harm, embarrassment,  inconvenience  or
             unfairness.

       k.     "Risk Analysis"  is a means of measuring and assessing the relative
             vulnerabilities ind threats to a collection of sensitive data ar.d the
             people,  systems and installations involved in storing and processing
             that data.  Its purpose is to determine how security measures can be
             effectively applied to minimize potential loss. Risk analyses may vary
             from an informal, quantitative review of a microcomputer installation to
             a formal, fully quantified review of a major computer center.

       I.      "Sensitive  Information" means information that requires protection due
             to the  risk and magnitude  of  loss or harm that could result from
             inadvertent or deliberate disclosure, alteration or  destruction of the
             information.    For the  purposes  of this  program,  information is
             categorized  as being  either sensitive or  not sensitive.   Because
             sensitivity is a matter of degree, certain sensitive information is further
             defined as being "highly" sensitive.

             Highly Sensitive:      This is information whose loss would seriously
                                  affect the Agency's ability to function, threaten
                                  the national security or jeopardize human life
                                  and welfare.  Specifically,  information of this
                                  type  includes  National Security Information,
                                  information  critical to the  performance of a
                                  primary Agency mission, information that is life

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                                   critical  and  financial  information related  to
                                   check issuance, funds  transfer and  simPar
                                   asset accounting/control functions.

             Other Sensitive:        This is information whose loss would acutely
                                   embarrass the Agency, subject the Agency to
                                   litigation  or impair the long-run ability of the
                                   Agency to fulfill its mission. Information of this
                                   type   includes   Privacy  Act   Information,
                                   Confidential   «   Business       Information,
                                   enforcement   v  confidential     information,
                                   information  that the Freedom of Information
                                   Act exempts from disclosure, budgetary data
                                   prior to  release by OMB and  information  of
                                   high value  to the Agency  or  a  particular
                                   organization (see below).

             The sensitivity if any, of all other information, shall  be determined by the
             organizational owner of the information. WhDe a  precise set of criteria
             for determining the sensitivity  of this  other  information cannot be
             provided, the cost of replacing the information and the problems that
             would result from doing without  the information are primary factors to
             consider in determining  sensitivity.

       m.    "Sensitive Applications  (or Systems)" are applications which process
             highly sensitive or sensitive information or are applications that require
             protection because of the loss  or harm which could result from the
             improper operation or deliberate manipulation of the application itself.
             Automated decision-making applications  are  highly sensitive if the
             wrong automated decision could cause serious loss.

8.     PROCEDURES AND GUIDELINES. Standards, procedures and guidelines for
the Agency information security program will be identified and issued under separate
cover in the "Information Security Manual." This manual will identify and reference,
as appropriate, existing procedures  in the information  security area, such as the
"Privacy Act Manual," the "National Security Information Security Handbook," and
Confidential Business Information manuals like the TSCA Security Manual."

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9.     PENALTIES FOR UNAUTHnRI7FD DISCLOSURE OF INFnRMAT|ON

       a.     EPA employees are subject to appropriate penalties if they knowingly,
             willfully or negligently disclose sensitive information to unauthorized
             persons.   Penalties may  include, but are not limited  to, a letter of
             warning, a letter of reprimand, suspension without pay, dismissal, loss
             or denial of access to sensitive information (including National Security
             Information), or other penalties in accordance with applicable law and
             Agency rules  and  regulations, which  can include criminal  or civil
             penalties.  Each case will be handled on an individual basis with a full
             review of all the pertinent facts.  The severity of the security violation or
             the pattern of violation will determine the action taken.

       b.     Non-EPA  personnel v/ho  knowingly,  willfully or negligently disclose
             sensitive  information to unauthorized  persons  will  be subject  to
             appropriate laws and sanctions.
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                               APPENDIX B
                  APPLICATION RISK ANALYSIS AND
                     APPLICATION CERTIFICATION

A.     THE CERTIFICATION PROCESS

Owners  should review Section 2.4,  which contains information on  combining
applications  for certification  purposes,  before proceeding  with  this  Appendix.
Owners should also note that in working through this Appendix a qualitative risk
analysis is performed, that is, relative vulnerabilities and threats are assessed and
safeguards are specified.

1.     New Applications

Each new sensitive application must undergo initial certification,  and then  re-
certification  every  three years.  This  certificp.don  must  take place  prior to the
application being put into use or production.  For sensitive  PC applications, the
certification or recertification will begin with the application owner's completion of the
Certification Worksheet, Exhibit B-1.    The  form and  specific  instructions  for
completing it are described below.  The Certifying Official, PC Site Coordinator, and
PC custodian will be available to answer owner questions on an as needed basis.

After  completing the  worksheet, the owner will forward  it to  his/her  immediate
supervisor for review.  The supervisor will review the  worksheet for completeness
and then forward it to the designated Certifying Official.

The Certifying Official will either certify that the application is adequately safeguarded
or deny certification by marking the appropriate box on the worksheet and returning
it to the supervisor.  A Certifying  Official may conclude that safeguards are adequate
if the application is protected in accordance with the procedures set forth in Sections
6-8 of this manual.  When certifying the application,  the Certifying Official must mark
the appropriate box on the worksheet and sign the  one-page certification statement
shown as Exhibit B-2. These documents must be retained on file for inspection by
OIRM, auditors, or the Office of the Inspector General.

Recertification of the operational application should be based  on reviews or audRs
that test and evaluate the adequacy of implemented  safeguards and that identify any
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                                  EXHIBIT B-1
                CERTIFICATION WORKSHEET AMD EXAMPLE
            SENSITIVE APPLICATION CERTIFICATION WORKSHEET
   1. APPLICATION TITLE
     RCRA Settlement Offers
                          2. OWNER
                             ImaSafe
                             OSWER, OSW
   3. TYPE(S) OF INFORMATION
     Enforcement confidential;
     high value
                             SENSITIVITY LEVEL ft OBJECTIVE
                             Confidential: Medium Level
                             Availability: Medium Level
   5. PROCESSING ENVIRONMENT
     Standalone; non-removable and
     removable media; shared user; Room 1123,
     West Tower, Washington, D.C.
                          6. DESCRIPTION
                             Database application that tracks
                             settlement offe ,-s by case. All
                             users of PC rr ay see confidential
                             data.
   7. SECURITY SPECIFICATIONS/REQUIREMENTS
         Controls to Maintain Availability
         - Back-up database to diskettes in accordance with the procedures manual.
         - Identify backup computing facility.
     b.   Controls to Maintain Integrity
         (Minimal controls only)
     c.   Controls to Maintain Confidentiality
         - Keep PC and removable media in a locked room.
         - Establish a formal list of authorized users.
   8. EVIDENCE OF ADEQUACY/DESIGN REVIEW
         Check to make sure door lock installed.
         Check to see that formal list of authorized users created.
         Are backups created by user?
         Memorandum outlining agreement for backup facility.
   9. TEST SCENARIO AND RESULT
         Lock installed on 6-15-89.
         List developed on 6-5-89.
         Local backups kept in adjacent office; archival backup stored in Crystal City.
         Memorandum with PC custodian in same branch executed 6-15-69.
   10.
CERTIFIED
NOT CERTIFIED
                                      B-2

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                               EXHIBIT B-2

                       CERTIFICATION STATEMENT
 I have carefully examined the information presented on the Certification Worksheet
 for   (application name)  . dated	.  Based on my authority and judgement,
 and weighing any remaining risks against operational requirements. I authorize con-
 tinued operation of   ^application name^   under the restrictions/conditions listed
 below.

             (List any Restrictions and Special Conditions fir enter "None")
                                          (Signature and Date)
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new vulnerabilities.   These  reviews or  audits  should be  considered part  of
vulnerability assessments and internal control reviews conducted in accordance with
OMB Circular No. A-123.

2.     Existing Applications

Each  existing sensitive  application  must also  undergo initial  certification (and
recertification every three years) in accordance with all  of the instructions above.
However, to avoid overwhelming organizations, initial certification may take place on
a phased basis over the next two years. All  initial certifications of existing systems
should be complete by the end of FY1991.  More sensitive applications (as defined
in Section 4) need to be certified first and as expeditiously as possible (by the  end of
1990).  Because of their overall organizational knowledge, SIRMOs may be able tj
quickly prioritize applications for certification.

B.     THE CERTIFICATION WORKSHEET

The certification worksheet should be completed by the application owner as follows.
The  numbers below correspond  to the numbered blocks on the worksheet.  The
worksheet has been filled in to provide an example of what is expected.

     1. Application Title: Provide the name of the information system or application.

    2. Owner:  List the application owner and organization.

    3. Type of Information:  Indicate the type of sensitive information (for example,
       CBI or high value) in terms of Section 4 of this manual.

    4. Sensitivity Level and Objective:  Provide  the relevant security objective (for
       example, availability) and the  associated sensitivity level (for example, high
       level).

    5. Processing Environment:  Describe the processing environment in terms of
       shared versus  single  user PC, removable  versus non-removable storage
       media,  and standalone  processing  versus  communicating  with  other
       equipment.  Also indicate  the physical  and geographic location  of the
       system.

    6.  Description: Provide a brief functional description of the application.

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    7(a)-(c).      Security Specifications/Requirements:   Express the needed
        availability,  integrity, and/or confidentiality security  controls in terms of
        Sections 6-8 of this manual.

    8.  Evidence of Adequacy/Design Review: Indicate how the owner will ensure
        that the security specifications are being implemented.

    9.  Test  Scenario  and  Results:    Describe  how  the  owner  will satisfy
        himself/herself that the safeguards work or that the procedures are being
        followed.
                                               i- *
   10.  Certifying blocks to be checked by the Certifying Officer as appropriate.

The application owner should note that the worksheet could also be used as & set of
security procedures for the application's users. In other words, the worksheet can
be  used  to  communicate  the  sensitivity  of the application and the  security
procedures to the user.
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                              APPENDIX C
                    INSTALLATION RISK  ANALYSIS

A.    BACKGROUND

A risk analysis is a means of measuring and assessing the relative vulnerabilities and
threats to an installation. Its purpose is to determine how security safeguards can be
effectively applied to minimize potential loss.  In everyday terms, risk analysis is
simply a procedure for identifying what could go wrong, how likely it is that things
could go wrong, and what can be done to prevent them from going wrong.

Risk analyses may vary from an informal, qualitative review of a microcomputer or
minicomputer installation, to a formal, fully quantified review of a major computer
center.  For all Agency installations, including PCs, a qualitative approach may be
used.

B.    APPLICABILITY AND REQUIRED SCHEDULE

All Agency PCs are  required to undergo a risk  analysis.  A risk analysis  shall be
performed:
     -  At the time the equipment is installed.
     •  Whenever a  significant  change occurs to  the installation.   Significant
       changes include:
          -  Physically moving the equipment to another location
          -  Going from a single user to multiple users, or vice versa
          -  Altering the communication  configuration,  for  example, adding a dial-
            up capability or becoming part of a LAN.
     •  At least  every  five years,  if no  significant  change  to the installation
       necessitating an earlier analysis has occurred.  Existing PCs that have not
       undergone a risk analysis during the last five years must undergo one by the
       end of 1990.
                                   C-1

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Information Security Manual for PCs
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                            EXHIBIT C-1

              RISK ANALYSIS WORKSHEET AND EXAMPLE
  1. PC LOCATION
    Room 1123, West Tower
    Washington, DC
    OSW
2. CUSTODIAN & EQUIPMENT TYPE
   R.U. Secure
   IBM PC/AT
  3. TYPE(S) OF INFORMATION
    Enforcement confidential;
    high value
4.  NUMBER OF SENSITIVE
   APPLICATIONS
      1
 5. PROCESSING ENVIRONMENT
    Standalone; non-removable and
    removable media; shared user
6.  SENSITIVITY LEVEL & OBJECTIVE
   Confidential:     Medium Level
   Availability:      Medium Level
 7.  CONTROLS TO MAINTAIN AVAILABILITY
    •  Remind users to backup data in accordance with the procedures manual.
    •  Execute a memorandum with another PC custodian outlining agreement
      for backup computing.
 8. CONTROLS TO PRESERVE INTEGRITY
    (Minimal controls only.)
 9.  CONTROLS TO PRESERVE CONFIDENTIALITY
    •  Install a door lock.
    •  Make sure application owner has established a list of authorized users.
 10. COMMENTS
    The procedures for all environ-
    ments described in Section 8.3.1
    have been implemented, except
    those related to passwords.
11. MINIMAL CONTROLS IN PLACE?

      x  YES         NO
                               C-2

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C.    RISK ANALYSIS WORKSHEET

To perform the qualitative risk analysis required by this manual, the PC custodian
should complete the worksheet shown as Exhibit C-1 as follows.  The numbers
below correspond to the numbered blocks on the worksheet.  The worksheet has
been filled in for a hypothetical PC to provide an example of what is expected.  Note
that the example involves the same application as that presented in Appendix B in
order to highlight the differences in security  perspective  between  owner  and
custodian.

     1.   Location and Equipment Type:   Provide the physical and  geographic
         location and the organization for the PC.

     2.   Custodian  and Equipment  Type:  List the person to whom the PC is
         assigned and the type of equipment.

     3.   Type of Information: Indicate the type o' sensitive information (for example,
         CBI  or high value) in terms of Section 4 of this manual. If the installation
         does not process any sensitive information, the risk analysis is at an end
         and   only  the  minimal  controls  set forth  in  Section  3 need to  be
         implemented.

     4.   Number of Sensitive Applications:   Indicate the  number of sensitive
         applications processed on the PC.

     5.   Processing Environment: Describe the processing environment in terms of
         shared versus single user PC, removable versus non-removable storage
         media,  and stand-alone processing versus  communicating with other
         equipment.

     6.   Sensitivity Level and Objective:  Provide the relevant security objective (for
         example, availability) and the associated sensitivity level (for example, high
         level).

     7.   Controls to Maintain Availability: Express the needed availability controls in
         terms of Section 6 of this manual.

     8.   Controls to Preservee Integrity:  Express the needed  integrity controls in
         terms of Section 7 of this manual.
                                    C-3

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      9.  Controls to Preserve Confidentiality:  Express the needed confidentiality
         controls in terms of Section 8 of this manual.
  .  10.  Comments: Self-explanatory.
    11.  Minimal Controls in Place:   Indicate whether or not the minimal physical
         and environmental controls described in Section 3 are in place.

D.     QUANTITATIVE RISK ANALYSIS
Detailed instructions for performing a quantitative risk analysis are contained in the
Agency's "Information Security Manual."
In essence, a quantitative risk analysis  is an exercise in cost/benefit analysis.
Specifically, it involves the following steps:
     •   Identify the asset to be protected (equipment, application, data, etc.).
     •   Determine the threats to the asset:
          - Natural, such as flood or  earthquake
          - Man-made, such as fraud or accidental error
     •   Determine the probability the threat  will be realized and  the  dollar  loss
        (replacement cost, damages,  etc.) if the threat is realized.  Manipulate the
        two numbers to obtain the annual loss expectancy (ALE).
     •   Calculate the cost of security safeguards.
     •   Compare the cost of safeguards with the ALE, and implement those controls
        that are cost-effective.
A simple example involving protecting a database from fire follows:
    •  Asset is data base with a replacement cost $20,000.
    •  Threat is fire.
    •   Rate of occurrence of fire is once every 50 years.
    •  Annual probability of fire is 2%.
    °  Annual Loss Expectancy is $400 (.02 x $20,000).
    •  Cost of  safeguard (fire extinguisher) is  $100 with  a  life of 5 years, or
       $20/year.
                                     C-4

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     •  Obtain the fire extinguisher because It is cost-effective ($20 versus $400).
                                    C-5

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