This is the accessible text file for GAO report number GAO-11-20 
entitled 'Information Security: National Archives and Records 
Administration Needs to Implement Key Program Elements and Controls' 
which was released on October 27, 2010. 

This text file was formatted by the U.S. Government Accountability 
Office (GAO) to be accessible to users with visual impairments, as 
part of a longer term project to improve GAO products' accessibility. 
Every attempt has been made to maintain the structural and data 
integrity of the original printed product. Accessibility features, 
such as text descriptions of tables, consecutively numbered footnotes 
placed at the end of the file, and the text of agency comment letters, 
are provided but may not exactly duplicate the presentation or format 
of the printed version. The portable document format (PDF) file is an 
exact electronic replica of the printed version. We welcome your 
feedback. Please E-mail your comments regarding the contents or 
accessibility features of this document to Webmaster@gao.gov. 

This is a work of the U.S. government and is not subject to copyright 
protection in the United States. It may be reproduced and distributed 
in its entirety without further permission from GAO. Because this work 
may contain copyrighted images or other material, permission from the 
copyright holder may be necessary if you wish to reproduce this 
material separately. 

Report to the Ranking Member, Committee on Finance, U.S. Senate: 

United States Government Accountability Office: 
GAO: 

October 2010: 

Information Security: 

National Archives and Records Administration Needs to Implement Key 
Program Elements and Controls: 

GAO-11-20: 

GAO Highlights: 

Highlights of GAO-11-20, a report to the Ranking Member, Committee on 
Finance, U.S. Senate. 

Why GAO Did This Study: 

The National Archives and Records Administration (NARA) is responsible 
for preserving access to government documents and other records of 
historical significance and overseeing records management throughout 
the federal government. NARA relies on the use of information systems 
to receive, process, store, and track government records. As such, 
NARA is tasked with preserving and maintaining access to increasing 
volumes of electronic records. 

GAO was asked to determine whether NARA has effectively implemented 
appropriate information security controls to protect the 
confidentiality, integrity, and availability of the information and 
systems that support its mission. To do this, GAO tested security 
controls over NARAís key networks and systems; reviewed policies, 
plans, and reports; and interviewed officials at nine sites. 

What GAO Found: 

NARA has not effectively implemented information security controls to 
sufficiently protect the confidentiality, integrity, and availability 
of the information and systems that support its mission. Although it 
has developed a policy for granting or denying access rights to its 
resources, employed mechanisms to prevent and respond to security 
breaches, and made use of encryption technologies to protect sensitive 
data, significant weaknesses pervade its systems. NARA did not fully 
implement access controls, which are designed to prevent, limit, and 
detect unauthorized access to computing resources, programs, 
information, and facilities. Specifically, the agency did not always 
(1) protect the boundaries of its networks by, for example, ensuring 
that all incoming traffic was inspected by a firewall; (2) enforce 
strong policies for identifying and authenticating users by, for 
example, requiring the use of complex (i.e., not easily guessed) 
passwords; (3) limit usersí access to systems to what was required for 
them to perform their official duties; (4) ensure that sensitive 
information, such as passwords for system administration, was 
encrypted so as not to be easily readable by potentially malicious 
individuals; (5) keep logs of network activity or monitor all parts of 
its networks for possible security incidents; and (6) implement 
physical controls on access to its systems and information, such as 
securing perimeter and exterior doors and controlling visitor access 
to computing facilities. 

In addition to weaknesses in access controls, NARA had mixed results 
in implementing other security controls. For example: 

* NARA did not always ensure equipment used for sanitization (i.e., 
wiping clean of data) and disposal of media (e.g., hard drives) was 
tested to verify correct performance. 

* NARA conducted appropriate background investigations for employees 
and contractors to ensure sufficient clearance requirements have been 
met before permitting access to information and information systems. 

* NARA did not consistently segregate duties among various personnel 
to ensure that no one person or group can independently control all 
key aspects of a process or operation. 

The identified weaknesses can be attributed to NARA not fully 
implementing key elements of its information security program. 
Specifically, the agency did not adequately assess risks facing its 
systems, consistently prepare and document security plans for its 
information systems, effectively ensure that all personnel were given 
relevant security training, effectively test systemsí security 
controls, consistently track security incidents, and develop 
contingency plans for all its systems. Collectively, these weaknesses 
could place sensitive information, such as records containing 
personally identifiable information, at increased and unnecessary risk 
of unauthorized access, disclosure, modification, or loss. 

What GAO Recommends: 

GAO is making 11 recommendations to the Archivist of the United States 
to implement elements of NARAís information security program. In 
commenting on a draft of this report, the Archivist generally 
concurred with GAOís recommendations but disagreed with some of the 
reportís findings. GAO continues to believe that the findings are 
valid. 

View [hyperlink, http://www.gao.gov/products/GAO-11-20] or key 
components. For more information, contact Gregory C. Wilshusen at 
(202) 512-6244 or wilshuseng@gao.gov and Dr. Nabajyoti Barkakati at 
(202) 512-4499 or barkakatin@gao.gov. 

[End of section] 

Contents: 

Letter: 

Background: 

Control Weaknesses Threaten Record Retention: 

Conclusions: 

Recommendations for Executive Action: 

Agency Comments and Our Evaluation: 

Appendix I: Objective, Scope, and Methodology: 

Appendix II: NARA Organizational Chart: 

Appendix III: Comments from the National Archives and Records 
Administration: 

Appendix IV: GAO Contacts and Staff Acknowledgments: 

Tables: 

Table 1: Major NARA Divisions: 

Table 2: Examples of Key NARA Systems: 

Table 3: Positions with Key Security Responsibilities in the Office of 
Information Services: 

Figures: 

Figure 1: Simplified NARA Network Diagram: 

Figure 2: User Completion of NARA Security Awareness Training: 

Abbreviations: 

CIO: Chief Information Officer: 

ERA: Electronic Records Archives: 

FIPS: Federal Information Processing Standard: 

FISMA: Federal Information Security Management Act: 

IT: information technology: 

NARA: National Archives and Records Administration: 

NIST: National Institute of Standards and Technology: 

OMB: Office of Management and Budget: 

POA&M: plan of action and milestones: 

US-CERT: United States Computer Emergency Readiness Team: 

[End of section] 

United States Government Accountability Office:
Washington, DC 20548: 

October 21, 2010: 

The Honorable Charles E. Grassley: 
Ranking Member: 
Committee on Finance: 
United States Senate: 

Dear Senator Grassley: 

The National Archives and Records Administration (NARA) is responsible 
for managing and archiving government records, which increasingly 
involves dealing with documents that are created and stored 
electronically. In 2001, NARA responded to the challenge of 
preserving, managing, and providing access to electronic records by 
initiating the development of the Electronic Records Archives (ERA). 

As the nation's record keeper, NARA is responsible for significant 
amounts of sensitive information. In 2009 NARA experienced a data 
breach wherein a hard drive containing data from the Clinton 
Administration was lost. The hard drive reportedly contained 
classified information and Social Security numbers of former White 
House staffers and visitors. 

In response to your request, we conducted an evaluation of NARA's 
information security program. Our objective was to determine whether 
NARA has effectively implemented appropriate information security 
controls to protect the confidentiality, integrity, and availability 
of the information and systems that support its mission. To accomplish 
this objective, we examined computer security controls over networks 
supporting nine sites to determine whether information was safeguarded 
and protected from unauthorized access. We also reviewed and analyzed 
NARA's security policies, plans, and reports and interviewed key 
agency officials. 

We performed this performance audit from December 2009 to October 
2010, in accordance with generally accepted government auditing 
standards. Those standards require that we plan and perform the audit 
to obtain sufficient, appropriate evidence to provide a reasonable 
basis for our findings and conclusions based on our audit objective. 
We believe that the evidence obtained provides a reasonable basis for 
our findings and conclusions based on our audit objective. See 
appendix I for a complete description of our objective, scope, and 
methodology. 

Background: 

Information security is a critical consideration for any organization 
reliant on information technology (IT) and especially important for 
government agencies, such as NARA, where maintaining the public's 
trust is essential. The dramatic expansion in computer 
interconnectivity and the rapid increase in the use of the Internet 
have changed the way our government, the nation, and much of the world 
communicate and conduct business. Although this expansion has created 
many benefits for agencies in achieving their missions and providing 
information to the public, it also exposes federal networks and 
systems to various threats. 

Without proper safeguards, systems are unprotected from attempts by 
individuals and groups with malicious intent to intrude and use the 
access to obtain sensitive information, commit fraud, disrupt 
operations, or launch attacks against other computer systems and 
networks. This concern is well-founded for a number of reasons, 
including the dramatic increase in reports of security incidents, the 
ease of obtaining and using hacking tools, the steady advance in the 
sophistication and effectiveness of attack technology, and the dire 
warnings of new and more destructive attacks to come. Over the past 
few years, federal agencies have reported an increasing number of 
security incidents, many of which involved sensitive information that 
has been lost or stolen, including personally identifiable 
information, which has exposed millions of Americans to the loss of 
privacy, identity theft, and other financial crimes. 

NARA Is a Key Steward of Federal Records: 

NARA is the nation's record keeper. It was created by statute as an 
independent agency in 1934. On July 1, 1949, the Federal Property and 
Administrative Services Act transferred the National Archives to the 
General Services Administration, and its name was changed to National 
Archives and Records Services. It attained independence again as an 
agency in October 1984 (effective April 1, 1985) and became known as 
the National Archives and Records Administration. NARA's mission is to 
ensure continuing access to essential documentation of the rights of 
American citizens and the actions of their government. NARA also 
publishes the Federal Register, stores classified materials, and plays 
a role in the declassification of these classified records. 

The Archivist of the United States is NARA's chief administrator and 
has responsibilities that include providing federal agencies with 
guidance and assistance for records management and establishing 
standards for records retention. The Archivist also has overall 
responsibility for ensuring the confidentiality, integrity, and 
availability of the information and information systems that support 
the agency and its operations. The Assistant Archivist for Information 
Services has the responsibilities of NARA's Chief Information Officer. 

In fiscal year 2009, NARA's appropriation was about $459 million, 
while its fiscal year 2010 appropriation is about $470 million. NARA 
is composed of six major divisions (see table 1) that include 44 
facilities such as the headquarters locations in Washington, D.C., and 
College Park, Maryland; presidential libraries; and regional archives 
nationwide. 

Table 1: Major NARA Divisions: 

Division: Office of Records Services, Washington, D.C.; 
Description of function: Accessions, preserves, describes, and 
provides access to the historically valuable records of the three 
branches of the federal government in the Washington, D.C., area. The 
office has agencywide responsibility for records appraisal. In 
addition, its conservation staff serves the entire agency and also 
operate the Washington National Records Center at Suitland, Maryland. 

Division: Office of Regional Records Services; 
Description of function: Accessions, preserves, describes, and 
provides access to the archival records of federal executive agencies 
that were created outside the Washington, D.C., area and the archival 
records of the U.S. District Courts within 13 regional archives 
centers nationwide, plus provides targeted assistance program to aid 
federal agencies with records management. The office serves as NARA 
liaison for the eight affiliated archives that hold NARA-owned records 
on behalf of NARA in their repositories around the country. 

Division: Office of Presidential Libraries; 
Description of function: Administers a nationwide network of 
presidential libraries documenting each administration beginning with 
the Herbert Hoover Administration. Currently, the system includes 13 
Presidential Libraries, Nixon Presidential Materials Staff, and 
Presidential Materials Staff. These are not traditional libraries, but 
rather repositories for preserving and making accessible the papers, 
records, and other historical materials of U.S. presidents. A museum 
is an important component of each library. 

Division: Office of the Federal Register; 
Description of function: Publishes public laws, coordinates the 
functions of the Electoral College, administers the constitutional 
amendment process, and provides access to the official text of federal 
laws, presidential documents, administrative regulations, and notices. 

Division: Office of Information Services; 
Description of function: Provides information technology services 
agencywide. Also manages the development of the ERA system. 

Division: Office of Administration; 
Description of function: Operates and maintains physical security, 
including the transfer of classified information. 

Source: NARA. 

[End of table] 

NARA Relies on Information Systems to Accomplish Its Mission: 

NARA depends on a number of key information systems to conduct its 
daily business functions and support its mission. These systems 
include networks, telecommunications, and specific applications. As of 
fiscal year 2009, NARA reported having 39 IT systems and 4 externally 
hosted systems. According to NARA, as part of its key transformation 
initiative, in 2001 the agency responded to the challenge of 
preserving, managing, and assessing electronic records by beginning 
the development of the modern Electronic Records Archives (ERA) 
system. This major information system is intended to preserve and 
provide access to massive volumes of all types and formats of 
electronic records, independent of their original hardware or 
software. NARA plans for the system to manage the entire life cycle of 
electronic records, from their ingestion through preservation and 
dissemination to customers. We have previously made numerous 
recommendations to NARA to improve its acquisition and monitoring of 
the system.[Footnote 1] 

Table 2 lists examples of key NARA systems. 

Table 2: Examples of Key NARA Systems: 

System: Electronic Records Archives (ERA); 
System location: Allegany Ballistics Laboratory; 
Description: Plans to authentically preserve electronic records and 
provide discovery and delivery of archived records. A component of 
ERA, the Executive Office of the President system, receives, archives, 
and disseminates presidential holdings. 

System: NARANET; 
System location: NARA-wide; 
Description: Provides data transport and processing environment for 
NARA's IT and application support services. 

System: Archives Declassification Review and Redaction System (ADRRES); 
System location: Archives II; 
Description: Indexes classified documents that have been withdrawn 
from records transferred to NARA and processes Freedom of Information 
Act requests for nonclassified material. 

System: Archival Electronic Records Inspection and Control System 
(AERIC); 
System location: Archives II; 
Description: Verifies the adequacy of the accompanying documentation 
for the electronic data files transferred by federal agencies to NARA. 

System: Archival Preservation System (APS); 
System location: Archives II; 
Description: Copies files from one volume to another, supports the 
business process of providing reference services, and provides 
management support for a variety of electronic records. 

System: Archival Research Catalog (ARC); 
System location: Archives II; 
Description: Provides an online catalog of NARA's holdings. 

System: Archives and Records Centers Information System (ARCIS); 
System location: Archives II; 
Description: Processes core transactions such as records transfers, 
accessions, dispositions, reference requests, refiles, and interfiles. 

System: Badging and Access (B&A); 
System location: Archives II; 
Description: Provides a means of transferring user information to a 
badge and physically reading the badge allowing or denying access 
depending on user access rights. 

System: Case Management and Reporting System (CMRS); 
System location: Archives II; 
Description: Automates the processing of military personnel records. 

System: Presidential Electronic Records Library System (PERL); 
System location: Archives II; 
Description: Provides a repository for electronic records produced 
during presidential administrations. 

Source: NARA. 

[End of table] 

The Office of Information Services at the Archives II facility 
provides centralized management and control of NARA's IT resources and 
services, including NARANET, the primary general support system of 
NARA. As shown in figure 1, NARANET is centrally located at Archives 
II and connects to other government and academic entities. NARANET is 
extended to field sites via a private network, operated by a service 
provider. In addition, at locations where the public has research 
access, NARA provides access to the Internet through the use of public 
access computers. 

Figure 1: Simplified NARA Network Diagram: 

[Refer to PDF for image: illustration] 

Internet (network): 
Feeds: 
* Military Personnel Records Center, St. Louis, MO; 
* NARANET (Located at Archives II, College Park, MD); includes public 
access computers (network); 
* Defense Research Engineering Network. 

NARANET: 
Feeds: 
* University of Maryland (network); 
* General Services Administration (network); 
* Defense Research Engineering Network (network); 
* NARANET Private (Virtual) (network). 

NARANET Private (Virtual): 
Feeds: 
* Allegany Ballistics Laboratory Rocket Center, WV (includes ERA 
network) (also fed by Defense Research Engineering Network); 
* Military Personnel Records Center, St. Louis, MO; 
* Civilian Personnel Records Center, St. Louis, MO; 
* Natíl Personnel Records Center Annex, Valmeyer, IL; 
* Archives I, Washington, DC; 
* Washington Natíl Records Center, Suitland, MD; 
* Clinton Presidential Library, Little Rock, AR (includes public 
access computers). 

Allegany Ballistics Laboratory Rocket Center: 
Feeds: 
* Contractor, Greenbelt, MD. 

Source: GAO analysis of agency data as of July, 2010. 

[End of figure] 

NARA's Information System Security Program: 

The Federal Information Security Management Act of 2002 (FISMA) 
[Footnote 2] requires each federal agency to develop, document, and 
implement an agencywide information security program to provide 
security for the information and information systems that support the 
operations and assets of the agency, including those provided or 
managed by other agencies, contractors, or other sources. FISMA 
requires the Chief Information Officer or comparable official at 
federal agencies to be responsible for developing and maintaining an 
information security program. 

The Office of Information Services centrally administers NARA's IT 
security program at the Archives II facility. The Assistant Archivist 
for Information Services, who also serves as the Chief Information 
Officer (CIO), is the head of the Office of Information Services. As 
described in table 3, NARA has designated certain senior managers or 
divisions at headquarters to fill the key roles in IT security 
designated by FISMA and agency policy. 

Table 3: Positions with Key Security Responsibilities in the Office of 
Information Services: 

Position: Deputy CIO; 
Key responsibilities: Assists the CIO in leading the agencywide IT 
program and carrying out the provisions of enacted IT legislation. In 
coordination with the CIO, manages all day-to-day functions of the IT 
and information resources management program divisions and staffs. 

Position: Chief Information Security Officer; 
Key responsibilities: Reports to the CIO and has day-to-day oversight 
of NARA's information security program. 

Position: IT Security Staff; 
Key responsibilities: Develops and implements NARA's IT Security 
Program Plan and the Computer Security Response Program. 

Position: Chief Technology Officer; 
Key responsibilities: Directs the planning, architecture, design, and 
configuration management of all agencywide hardware, software, 
database management systems, telecommunications, data and local area 
and wide area networks, and related equipment and approves systems 
development methodologies and configuration changes to NARA's 
technology infrastructure. 

Position: Information Technology Services Division Director; 
Key responsibilities: Administers the operation of NARA's IT 
infrastructure, including voice and data communications systems, by 
NARA staff and contractors. 

Position: IT Services Branch Manager; 
Key responsibilities: Provides contracting officer's representative 
services for the Information Technology Support Systems contract, 
NARA's nationwide network operations contract. 

Position: IT Operations Branch Manager; 
Key responsibilities: Operates, maintains, and manages NARA's IT 
network infrastructure, voice and data communications systems, and IT 
security operations (in conjunction with IT security staff). Also 
monitors NARA network and desktop environments for performance. 

Source: NARA. 

[End of table] 

FISMA also requires the National Institute of Standards and Technology 
(NIST) to provide standards and guidance to agencies on information 
security. NARA has a directive in place to establish its policy and 
guidance for information security, delineate its security program 
structure, and assign security responsibilities. 

Control Weaknesses Threaten Record Retention: 

NARA has taken steps to safeguard the information and systems that 
support its mission. For example, it has developed a policy for 
granting or denying access rights to its resources, employs mechanisms 
to prevent and respond to security breaches, and makes use of 
encryption technologies to protect sensitive data. 

However, security control weaknesses pervaded NARA's systems and 
networks, thereby jeopardizing the agency's ability to sufficiently 
protect the confidentiality, integrity, and availability of its 
information and systems. These deficiencies include those related to 
access controls, as well as other controls such as configuration 
management and segregation of duties. A key reason for these 
weaknesses is that NARA has not yet fully implemented its agencywide 
information security program to ensure that controls are appropriately 
designed and operating effectively. These weaknesses could affect 
NARA's ability to collect, process, and store critical information and 
records, and protect that information from risk of unauthorized use, 
modification, and disclosure. 

NARA Did Not Fully Implement Access Controls: 

A basic management objective for any organization is to protect the 
resources that support its critical operations from unauthorized 
access. Organizations accomplish this by designing and implementing 
controls that are intended to prevent, limit, and detect unauthorized 
access to computing resources, programs, information, and facilities. 
Inadequate access controls diminish the reliability of computerized 
information and increase the risk of unauthorized disclosure, 
modification, and destruction of sensitive information and of 
disruption of service. Access controls include those related to (1) 
protection of system boundaries, (2) user identification and 
authentication, (3) authorization, (4) cryptography, (5) audit and 
monitoring, and (6) physical security. NARA did not implement 
effective controls in these areas. 

NARA Did Not Always Protect Network Boundaries: 

Boundary protection controls logical connectivity into and out of 
networks and controls connectivity to and from network connected 
devices. Unnecessary connectivity to an organization's network 
increases not only the number of access paths that must be managed and 
the complexity of the task, but the risk of unauthorized access in a 
shared environment. NIST guidance states that boundary protection 
devices should monitor and control communications at the external 
boundary of the system and at key internal boundaries within the 
system. Organizations use boundary protection devices such as proxies, 
gateways, routers, and firewalls to monitor and control such 
communications and to separate network segments that require a higher 
level of control than other segments of the network. 

NARA has established network boundaries, but did not always adequately 
enforce those boundaries to secure connectivity into and out of its 
networks. For example, at one location, network boundaries were not 
adequately segregated or segmented since NARA's network was not 
separated from a contractor network. In addition, several internal 
network routers allowed direct network connections from outside the 
network. Similarly, firewalls at two locations were not adequately 
configured to control traffic into those networks, which could also 
allow traffic to bypass the firewalls and enter those networks. We 
also discovered several devices connected to a network that NARA 
network engineers were not aware of that could result in unidentified 
attacks on the network by using those devices. As a result, NARA's 
networks were vulnerable to unnecessary and potentially undetectable 
access at multiple points. 

Users Were Not Always Properly Identified and Authenticated: 

A computer system must be able to identify and authenticate different 
users so that activities on the system can be linked to specific 
individuals. Assigning unique user accounts enables a system to 
distinguish one user from another (identification), while requesting 
specific information, such as a password, known only by a specific 
user allows a system to establish the validity of a user's claimed 
identity (authentication). The combination of identification and 
authentication--such as user account-password combinations--provides 
the basis for maintaining individual accountability and controlling 
access to a system. NIST states that information systems uniquely 
identify and authenticate users by, among other things, establishing 
complex (i.e., not easily guessed) passwords to reduce the likelihood 
of unauthorized access. 

While NARA has developed a policy for identification and 
authentication that is based on NIST guidance, NARA has not always 
adequately implemented its policy. For example, multiple database 
systems at one location were not adequately configured to identify 
users and authenticate their identities when users logged in remotely. 
At one location, NARA also established shared, or "generic," accounts 
with administrator privileges on multiple systems. This practice 
diminishes NARA's ability to establish individual accountability and 
attribute system activity to a specific individual. In addition, NARA 
does not always enforce policies for establishing complex passwords on 
multiple systems and applications. As a result, increased risk exists 
that individuals may guess passwords and use them to gain unauthorized 
access to NARA's systems and networks. 

Authorizations Provided Users with More Access than Necessary for 
Their Jobs: 

Authorization is the process of granting or denying access rights and 
permissions to a protected resource, such as a network, a system, an 
application, a function, or a file. A key concept for granting or 
denying access rights is that of "least privilege," which means that 
users should be granted only those access rights and permissions that 
they need to perform their official duties. NIST states that federal 
agencies should grant users only the access rights and privileges to 
information and information systems that are necessary for them to 
perform their jobs. 

Although NARA has established an access control methodology based on 
least privilege and need-to-know principles, it has not always limited 
users' access rights and permissions to those necessary for them to 
perform their official duties. At one location, NARA provided all 
users on a system with read-only access to a file containing system 
passwords. 

NARA also allowed remote root[Footnote 3] (e.g., "super-user") logins 
to multiple servers. NARA did not disable source routing[Footnote 4] 
on network devices. In addition, at two locations in our review, NARA 
granted administrator-level roles and privileges to normal user 
accounts for databases, which could lead to compromise of database 
servers. The result of these weaknesses is an increased risk of 
unauthorized access to NARA systems and information. 

NARA Did Not Always Use Encryption to Effectively Protect Sensitive 
and Critical Information: 

Cryptography is a fundamental mechanism used to protect the 
confidentiality and integrity of critical and sensitive information. 
Encryption, a basic element of cryptology, involves the conversion of 
data into a form (cipher text) that cannot be easily understood by 
unauthorized individuals. This is done by transforming plain text into 
cipher text using a special value (a "key") and a mathematical process 
known as an algorithm. NIST states that federal organizations should 
use encryption to protect the confidentiality of remote access 
sessions and encrypt sessions between host systems. In addition, NIST 
states that organizations should encrypt passwords in storage and 
transmission. For encryption employed on stored information such as 
passwords as part of an access enforcement mechanism, the cryptography 
used should comply with the Federal Information Processing Standard 
(FIPS) 140-2, as amended, Security Requirements for Cryptographic 
Modules.[Footnote 5] 

NARA did not always use encryption when sensitive information was 
stored or transmitted. For example, at two locations, NARA used 
unencrypted protocols for remote management of its network, which 
exposed sensitive authenticating session data. In another example, 
unencrypted passwords for authenticating users were transmitted across 
NARA's network. For several systems, NARA used weak password 
encryption that could be easily compromised and was not compliant with 
FIPS 140-2 algorithms for password encryption. NARA also allowed keys 
(the values used to transform plain text into cipher text) to be 
stored unencrypted. These weaknesses unnecessarily expose critical and 
sensitive information to risk of unauthorized access, modification, or 
destruction. 

Network Monitoring Was Not Consistently Implemented: 

To establish individual accountability, monitor compliance with 
security policies, and investigate security violations, it is crucial 
to determine what, when, and by whom specific actions have been taken 
on a system. To do this, organizations implement system or security 
software that provides an audit trail, or log, of system activity that 
can be used to determine the source of a transaction or attempted 
transaction and to monitor users' activities. Audit and monitoring 
technologies include network-and host-based intrusion detection 
systems, audit logging, security event correlation tools, and computer 
forensics. NIST guidance and NARA policy state that audit logs should 
be retained to allow monitoring of key activities, provide support for 
after-the-fact investigations of security incidents, and meet 
organizational information retention requirements. 

Although NARA has many useful mechanisms at its disposal to help 
prevent and respond to security breaches, such as firewalls and 
intrusion detection systems, it has not consistently implemented 
integrated and responsive auditing and monitoring. At one location, 
audit logs for network devices did not capture sufficient levels of 
information and were not in compliance with NARA's 1-year retention 
policy for system logs. For example, over 100 network devices were not 
configured for remote logging, and about 65 devices did not capture 
information such as logs of access control lists or successful and 
failed login attempts. At two locations, NARA had not adequately 
configured auditing on several systems supporting major applications, 
and database systems did not archive logs in conformity with NARA's 
retention policy. NARA also did not have an operational program in 
place for detecting "rogue" access points on its wireless networks, 
which could allow for undetected access. As a result, NARA is limited 
in its ability to establish accountability, ensure compliance with 
security policies, and investigate violations. 

Deficient Physical Security and Environmental Safety Controls Reduced 
Their Effectiveness: 

Physical security controls are a key component of limiting 
unauthorized access to sensitive information and information systems. 
These controls are important for protecting computer facilities and 
resources from espionage, sabotage, damage, and theft. They involve 
restricting physical access to computer resources and sensitive 
information, usually by limiting access to the buildings and rooms in 
which the resources are housed and periodically reviewing access 
rights granted to ensure that access continues to be appropriate based 
on established criteria. NIST states that federal organizations should 
implement physical security and environmental safety controls to 
protect employees and contractors, information systems, and the 
facilities in which they are located. NARA policy also requires 
controls for deterring and restricting physical access to areas 
housing sensitive IT equipment and information. 

NARA effectively secured several of its sensitive areas and computer 
equipment and took other steps to provide physical security and 
environmental safety. For example, NARA issued electronic badges to 
help control access to many of its sensitive and restricted areas. The 
agency also drafted policies and procedures to guide staff in securing 
sensitive information and IT resources. In addition, the agency 
implemented several environmental and safety controls, such as 
temperature and humidity controls, as well as fire protection to 
protect its staff and sensitive IT resources. 

However, NARA has not effectively: 

* secured interior areas with IT equipment and sensitive information 
and enforced physical security safeguards; 

* secured perimeter and exterior doors and controlled keys to facility 
doors; 

* prevented and controlled unauthorized removal of sensitive 
information and IT components; 

* authorized, authenticated, and controlled visitors to its facilities 
and areas containing sensitive IT equipment; 

* secured locations that support computer operations; and: 

* environmentally protected areas containing sensitive IT equipment. 

* These weaknesses in NARA's physical security and environmental 
safety controls put sensitive information and IT resources at risk. As 
such, NARA facilities may be vulnerable to attack or access by 
unauthorized individuals, and sensitive information could be stolen, 
damaged, or otherwise compromised. Also, because areas containing 
sensitive IT and support equipment are not adequately protected, NARA 
has less assurance that computing resources are protected from 
inadvertent or deliberate misuse including sabotage, vandalism, theft, 
and destruction. 

Weaknesses in Other Controls Increase Risk: 

In addition to access controls, other important controls should be in 
place to ensure the confidentiality, integrity, and availability of an 
organization's information. These controls include policies, 
procedures, and techniques for securely configuring information 
systems, sufficiently disposing of media, implementing personnel 
security, and segregating incompatible duties. Weaknesses in these 
areas increase the risk of unauthorized use, disclosure, modification, 
or loss of sensitive information and information systems supporting 
NARA's mission. 

Configuration Management Controls Were Not Sufficient: 

One of the purposes of configuration management is to establish and 
maintain the integrity of an organization's work products. It involves 
identifying and managing security features for all hardware, software, 
and firmware components of an information system at a given point and 
systematically controlling changes to that configuration during the 
system's life cycle. By implementing configuration management and 
establishing and maintaining baseline configurations and monitoring 
changes to these configurations, organizations can better ensure that 
only authorized applications and programs are placed into operation. 
NARA policy requires the most restrictive mode possible of the 
security settings of information technology products. NIST standards 
state and NARA policy requires system changes to be controlled. Patch 
management is an additional component of configuration management, and 
is an important factor in mitigating software vulnerability risks. Up-
to-date patch installation can help diminish vulnerabilities 
associated with flaws in software code. NIST states that organizations 
should promptly install newly released security relevant patches, 
service packs, and hot fixes and test them for effectiveness and 
potential side effects on the organization's information systems. 

NARA had not securely configured several of its systems. For example, 
network configurations were not always restricted in accordance with 
best practices; additionally, Web applications and operating systems 
were not always restricted in accordance with NIST guidance. 

While NARA has maintained and tracked configuration changes for its 
ERA system, it has not consistently documented the status of those 
changes. NARA documented, maintained, and tracked approvals for ERA's 
system change requests in its meeting minutes as well as in a system 
for managing those change requests, but the information in meeting 
minutes and the change repository were inconsistent. For example, 
change requests agreed to in meeting minutes from October 2009 to 
March 2010 did not always match those entered in the repository 
storing those changes. Specifically, some change requests were 
approved for implementation in the meeting, but were listed in the 
repository as closed. Others were reflected as being on hold, but were 
actually listed as canceled in the repository. According to ERA 
configuration management staff, these inconsistencies exist because 
the configuration control board status represents a single point in 
time of each change request. Subsequent changes to the system related 
to each change request are handled by release management staff. 
Therefore, the status in the repository will continue to change. 
Configuration management staff have the responsibility to document 
updates to changes in status at various points in the process. 

In addition, NARA had not implemented an effective patch management 
program for the systems we reviewed. For example, patches had not been 
consistently applied to critical systems or applications in a timely 
manner. Specifically, several critical systems had not been patched or 
were out of date, some of which had known vulnerabilities. 
Additionally, NARA used out-of-date or unsupported software and 
products in some instances. 

As a result of these control deficiencies, increased risk exists that 
the integrity of NARA systems could be compromised. 

NARA Did Not Consistently Test Equipment Used to Sanitize Media: 

Media destruction and disposal is key to ensuring confidentiality of 
information. Media can include magnetic tapes, optical disks (such as 
compact disks), and hard drives. Organizations safeguard used media to 
ensure that the information they contain is appropriately controlled. 
Media that is improperly disposed of can lead to the inappropriate or 
inadvertent disclosure of an agency's sensitive information or the 
personally identifiable information of its employees and customers. 
NARA uses degaussers[Footnote 6] to remove sensitive information from 
hard drives and tapes before reuse or destruction. This equipment 
should then be certified that it was tested and that it performed 
correctly. NIST recommends that organizations test 
sanitization[Footnote 7] equipment and procedures to verify correct 
performance. NARA's policy for protection of media requires that 
sanitization equipment be tested annually. 

However, NARA has not always ensured that equipment used for removing 
sensitive information was tested annually. For example, while the 
degausser located at one location was certified annually, one at 
another location was not. Specifically, one degausser was certified on 
January 2010, while the other had not been certified since July 2008, 
about 20 months prior to our on-site visit. By not testing and 
certifying its degausser, NARA has reduced assurance that the 
equipment is performing according to certified requirements. 

Personnel Security Controls Are in Place: 

The greatest harm or disruption to a system comes from the actions, 
both intentional and unintentional, of individuals. These intentional 
and unintentional actions can be reduced through the implementation of 
personnel security controls. According to NIST, personnel security 
controls help organizations ensure that individuals occupying 
positions of responsibility (including third-party service providers) 
are trustworthy and meet established security criteria for those 
positions. For employees and contractors assigned to work with 
confidential information, confidentiality, nondisclosure, or security 
access agreements specify required precautions, acts of unauthorized 
disclosure, contractual rights, and obligations during employment and 
after termination. NARA's security policy for personnel screening 
states that the type of investigation is based on the sensitivity of 
the position to be held. 

NARA conducted the appropriate background investigations for the 
employees and contractors we reviewed. These individuals also had 
appropriate nondisclosure agreements signed when applicable to their 
position. However, at one location contractors had not signed 
nondisclosure agreements for the ERA system. NARA staff acknowledged 
the issue and subsequently had the contractors sign the nondisclosure 
agreements. 

Incompatible Duties Were Not Always Effectively Segregated: 

Segregation of duties refers to the policies, procedures, and 
organizational structures that help ensure that no single individual 
can independently control all key aspects of a process or computer- 
related operation and thereby gain unauthorized access to assets or 
records. Often, organizations achieve segregation of duties by 
dividing responsibilities among two or more individuals or 
organizational groups. This diminishes the likelihood that errors and 
wrongful acts will go undetected, because the activities of one 
individual or group will serve as a check on the activities of the 
other. Effective segregation of duties includes segregating 
incompatible duties and maintaining formal operating procedures, 
supervision, and review. Inadequate segregation of duties increases 
the risk that erroneous or fraudulent transactions could be processed, 
improper program changes implemented, and computer resources damaged 
or destroyed. For systems categorized as high or moderate impact, 
[Footnote 8] NIST states that incompatible duties should be 
segregated, such as, by not allowing security personnel who administer 
system access control functions to administer audit functions. NARA 
also has a policy requiring segregation of duties. 

NARA did not always implement effective segregation of duties 
controls. For example, two staff members were each assigned security 
and system administration roles and responsibilities, as either a 
primary or backup for the ERA system (a high impact system). In 
addition, those individuals had privileges that allowed them to delete 
logs generated by the system used for auditing and logging security 
events. According to NARA staff, periodic reviews of the 
administrators' access were performed using checklists that require 
administrators to review each other's access activities. However at 
the time of our review, NARA had not documented its oversight process 
to ensure controls for separation of duties were implemented 
appropriately. As a result, NARA may face an increased risk that 
improper program changes or activities could go unnoticed. 

NARA Has Not Fully Implemented All Elements of Its Information 
Security Program: 

A key reason for the weaknesses in information security controls 
intended to protect NARA's systems is that the agency has not yet 
fully implemented its agencywide information security program to 
ensure that controls are effectively established and maintained. FISMA 
requires each agency to develop, document, and implement an 
information security program that, among other things, includes: 

* periodic assessments of the risk and the magnitude of harm that 
could result from the unauthorized access, use, disclosure, 
disruption, modification, or destruction of information and 
information systems; 

* policies and procedures that (1) are based on risk assessments, (2) 
cost-effectively reduce risks, (3) ensure that information security is 
addressed throughout the life cycle of each system, and (4) ensure 
compliance with applicable requirements; 

* plans for providing adequate information security for networks, 
facilities, and systems; 

* security awareness training to inform personnel of information 
security risks and of their responsibilities for complying with agency 
policies and procedures, as well as training personnel with 
significant security responsibilities for information security; 

* periodic testing and evaluation of the effectiveness of information 
security policies, procedures, and practices, which is to be performed 
with a frequency depending on risk, but no less than annually, and 
which includes testing the management, operational, and technical 
controls for every system identified in the agency's required 
inventory of major information systems; 

* a process for planning, implementing, evaluating, and documenting 
remedial action to address any deficiencies in its information 
security policies, procedures, or practices; 

* procedures for detecting, reporting, and responding to security 
incidents; and: 

* plans and procedures to ensure continuity of operations for 
information systems that support the operations and assets of the 
agency. 

Although NARA has developed and documented a framework for its 
information security program, key components of the program have not 
been fully or consistently implemented. 

NARA Developed Risk Assessments but Inconsistently Implemented Risk- 
Related Procedures: 

In order for agencies to determine what security controls are needed 
to protect their information resources, they must first identify and 
assess their information security risks. FIPS publication 199 provides 
risk-based criteria to identify and categorize information and 
information systems based on their impact to the organization's 
mission.[Footnote 9] In addition, the Office of Management and Budget 
(OMB) states that a risk-based approach is required to determine 
adequate security, and it encourages agencies to consider major risk 
factors, such as the value of the system or application, threats, 
vulnerabilities, and the effectiveness of current or proposed 
safeguards. By increasing awareness of risks, these assessments can 
generate support for policies and controls. NIST states that 
organizations should also assess physical security risks to their 
facilities when they perform required risk assessments of their 
information systems. Federal standards[Footnote 10] require that NARA 
conduct vulnerability risk assessments at least every 3 years for the 
buildings and facilities we visited. 

NARA has developed and conducted risk assessments, but has not 
consistently documented risk or assessed risk in a timely manner at 
its facilities. For example, NARA had developed risk assessments for 
all 10 of the systems in our review, but other system documentation 
for 4 of the 10 systems cited FIPS 199 impact levels that did not 
match those listed in NARA's systems inventory. Documents for 3 
systems reflected impact ratings higher than those listed in the 
systems inventory and the fourth one reflected a lower rating. 
Similarly, while NARA had conducted physical security risk assessments 
for the sites we reviewed, several had not been conducted within the 
required 3-year time frame. As a result, NARA may not have assurance 
that adequate controls are in place to protect its information and 
information systems. 

NARA's Policies and Procedures Were Not Always Consistent with Federal 
Guidance: 

Another key element of an effective information security program is to 
develop, document, and implement risk-based policies, procedures, and 
technical standards that govern security over an agency's computing 
environment. FISMA requires agencies to develop and implement policies 
and procedures to support an effective information security program. 
If properly implemented, policies and procedures should help reduce 
the risk that could come from unauthorized access or disruption of 
services. Developing, documenting, and implementing security policies 
are the primary mechanisms by which management communicates its views 
and requirements; these policies also serve as the basis for adopting 
specific procedures and technical controls. 

NARA has developed information security policies and procedures that 
are based on NIST guidelines. For example, NARA has developed 
individual policy documents that address all of the families of 
controls listed in NIST Special Publication 800-53.[Footnote 11] To 
illustrate, NARA has developed information security methodologies that 
correspond to the controls required by NIST in the areas of access 
controls, configuration management, contingency planning, and security 
awareness training. 

However, NARA's policies and procedures were not always consistent 
with NIST guidance. For example, NARA has not always prescribed 
controls based on the system's impact. NIST requires organizations to 
determine their information systems' impact using the security 
objectives of confidentiality, integrity, and availability and states 
that this information system impact level must be determined prior to 
the consideration of minimum security requirements and the selection 
of security controls for those information systems. Instead, NARA 
prescribed controls based on individual security objectives without 
taking into consideration the predetermined impact level (based on the 
three security objectives) of an individual system. To illustrate, 
NARA's access control policy only specifies controls for systems with 
moderate or high confidentiality, rather than suggesting controls 
according to the impact of the system, as determined by all three 
security objectives. Similarly, NARA's certification and accreditation 
and contingency planning methodologies prescribed controls for systems 
with moderate or high integrity and availability, respectively, and 
not based on the impact level of the system. As a result, NARA's 
policy may not provide the information needed to ensure that 
appropriate systems controls are selected that protect its information 
systems. 

Security Plans Contained Varying Levels of Information and Did Not 
Always Address Required Controls: 

An objective of system security planning is to improve the protection 
of information technology resources. A system security plan provides 
an overview of the system's security requirements and describes the 
controls that are in place--or planned--to meet those requirements. 
OMB Circular No. A-130 requires that agencies develop system security 
plans for major applications and general support systems, and that 
these plans address policies and procedures for providing management, 
operational, and technical controls.[Footnote 12] NIST Special 
Publication 800-53 states that the security plan should be updated to 
address changes to the system, its environment of operation, or 
problems identified during plan implementation or security control 
assessments. One of the controls recommended by NIST Special 
Publication 800-53 is the development of an inventory of an 
information system's components. This inventory should, among other 
things, accurately reflect the current information system, be 
consistent with the authorized boundary of the system, and be 
available for review. NARA's Security Architecture Planning 
Methodology also outlines security responsibilities, including 
responsibilities for information system owners and information owners 
to carry out related to system security plans. This methodology in 
turn mandates the use of baseline controls identified by NIST in 
Special Publication 800-53.[Footnote 13] 

NARA prepared and documented security plans for the 10 systems and 
networks we reviewed. All system security plans that we reviewed, with 
the exception of NARANET's wireless plan, identified management, 
technical, and operational controls, in accordance with NIST guidance 
and NARA policy. 

However, NARA did not always include required controls in its system 
security plans. For example, 7 of the 13 system security plans 
[Footnote 14] reviewed did not include a system component inventory or 
address where that inventory could be found. In addition, NARA has not 
updated its badge and access system security plan since 2003, despite 
replacing the system in 2007. NARA had scheduled to correct this 
weakness by the end of 2009, but as of September 2010 it had not been 
corrected. Further, NARA system security plans varied in documenting 
security roles and responsibilities for key individuals. Some plans 
were missing one or more assignments for these roles. Specifically, 6 
of the 13 plans did not have the required information system owner 
role identified, and none of the plans reviewed had the information 
owner role identified or assigned. 

By not addressing inventory control and assigning key security 
responsibilities in the system security plan, NARA increases the risk 
that critical information may not be available to those responsible 
for implementing system security plans, potentially causing a 
misapplication of controls to the system. 

Security Awareness Training and Specialized Security Training Were Not 
Effectively Tracked: 

According to FISMA, an agencywide information security program must 
include security awareness training for agency personnel, contractors, 
and other users of information systems that support the agency's 
operations and assets. This training must cover (1) information 
security risks associated with users' activities and (2) users' 
responsibilities in complying with agency policies and procedures 
designed to reduce these risks. FISMA also includes requirements for 
training personnel with significant responsibilities for information 
security. In addition, OMB requires that personnel be trained before 
they are granted access to systems or applications. The training is 
intended to ensure that personnel are aware of the system or 
application's rules, their responsibilities, and their expected 
behavior. Further, NARA policy requires that managers and users of 
NARA information systems be made aware of the security risks 
associated with their activities and of the applicable laws, executive 
orders, directives, policies, standards, instructions, regulations, or 
procedures related to the security of NARA information systems. The 
policy also states that NARA must ensure that personnel are adequately 
trained to carry out their assigned information security-related 
duties and responsibilities. 

NARA has a security awareness training program in place and maintains 
records of this training in its Learning Management System. Users are 
required to complete a Web-based course and, after completion, 
acknowledge they have reviewed and understand their security 
responsibilities. According to NARA's fiscal year 2009 FISMA report, 
the CIO reported that 100 percent of NARA's employees had received 
security awareness training. NARA's Inspector General concurred with 
this assessment. The CIO also reported that 50 employees had 
significant security responsibilities, and that all 50, had received 
specialized training. NARA's Inspector General reported a higher 
number stating that 114 employees had significant security 
responsibilities, and that 83 (73 percent) received specialized 
training. 

However, records from NARA's training system indicated that not all 
users had both completed the training and acknowledged that they 
reviewed and understood their security responsibilities in fiscal year 
2009. According to NARA's records, as of August 20, 2009, 563 of 4,536 
[Footnote 15] individuals had completed only the class portion (12 
percent) and 369 individuals (8 percent) had completed only the 
acknowledgment portion (although in many cases had at least started 
the class portion). Seven hundred and forty-nine individuals (17 
percent) had not completed either portion (see figure 2). 

Figure 2: User Completion of NARA Security Awareness Training: 

[Refer to PDF for image: pie-chart] 

Only acknowledgment portions: 8%; 
Only class portions: 12%; 
Both portions: 63%; 
None: 17%. 

Source: GAO analysis of NARA data. 

[End of figure] 

According to NARA's Chief Information Security Officer, limitations in 
the training tracking system led NARA to give credit for a user 
interacting with the system in some way, meaning that a user who had 
at least started the training course received credit for the security 
awareness training. In addition, records of specialized security 
training provided by NARA indicated that 115 individuals were required 
to take specialized security training; of these 115, 48 (42 percent) 
had no record of taking specialized training. NARA officials stated 
that these individuals were provided with an alternate form of 
training to ensure their compliance with FISMA, such as a one-on-one 
review or an opportunity to review briefing slides. 

Without an effective method for tracking that employees and 
contractors fully complete security awareness training, NARA has less 
assurance that staff are aware of the information security risks and 
responsibilities associated with their activities. In addition, 
without ensuring that all employees with specialized security 
responsibilities receive adequate specialized training, NARA's ability 
to implement security measures effectively could be limited. 

NARA Did Not Fully Test Controls: 

A key element of an information security program is to test and 
evaluate policies, procedures, and controls to determine whether they 
are effective and operating as intended. This type of oversight is 
fundamental because it demonstrates management's commitment to the 
security program, reminds employees of their roles and 
responsibilities, and identifies and mitigates areas of noncompliance 
and ineffectiveness. FISMA requires that the frequency of tests and 
evaluations of management, operational, and technical controls be 
based on risks and occur no less than annually. OMB requires that 
systems be authorized for processing at least every 3 years. NARA's 
policy for testing is consistent with FISMA and requires that 
certification testing be conducted in support of system authorizations 
or accreditations. 

NARA had conducted tests for each of the 10 systems we reviewed; 
however, it had not sufficiently tested controls for 2 systems. For 
example, the management and operational controls for 1 system were not 
tested at least annually. Although NARA tested technical controls and 
documented test results for that system, it did not test and document 
the results for the system's management and operational controls. 
Another system had not been tested to support its accreditation since 
2003. While an annual assessment was conducted in 2009 for that 
system, NARA's 2007 security accreditation memorandum stated that 
certification testing had not been performed. As a result, NARA may 
have reduced assurance that controls over its information and 
information systems are adequately implemented and operating as 
intended. 

Remedial Action Plans Were Not Reliably Maintained: 

Remedial action plans, also known as plans of action and milestones 
(POA&M), help agencies identify and assess security weaknesses in 
information systems, set priorities, and monitor progress in 
correcting the weaknesses. NIST guidance states that each federal 
civilian agency must report all incidents and internally document 
remedial actions and their impact. POA&Ms should be updated to show 
progress made on current outstanding items and to incorporate the 
results of the continuous monitoring process. In addition, FISMA and 
NARA policy require the agency CIO to report annually to the agency 
head on the effectiveness of the agency information security program, 
including progress on remedial actions. 

NARA has implemented a remedial action process to assess and correct 
security weaknesses. The format for its system-level POA&Ms includes 
the types of information specified in NIST and OMB guidance, such as a 
description of the weakness, resources required to mitigate it, 
scheduled completion date, the review that identified the weakness, 
and the status of corrective actions (ongoing or completed). 

Although NARA has developed POA&Ms to address known weaknesses, the 
agency does not always update these plans or complete remedial actions 
in a timely manner. For example, a POA&M for a system designed to 
receive, preserve, and provide access to electronic records is dated 
December 2008. None of the remedial actions described in this plan 
were marked as completed as of April 2010. Additionally, 8 of 10 
POA&Ms that we assessed contained blank entries or "to be determined" 
notations for some required information. These 8 did not provide all 
of the information for resources needed, scheduled completion dates, 
milestones, or the security review that identified the weakness. 

In addition, a POA&M maintained by the Office of Information Services 
did not include information about resources required to correct these 
weaknesses. This lack of information about resource requirements may 
inhibit the agency's efforts to correct the security weaknesses. 
Outdated and incomplete POA&Ms compromise the ability of the CIO and 
other NARA officials to track, assess, and report accurately the 
status of the agency's information security. 

Security Incident Tracking Was Inconsistent: 

Although strong controls may not block all intrusions and misuse, 
agencies can reduce the risks associated with such events if they take 
steps to detect and respond to them before significant damage occurs. 
Accounting for and analyzing security problems and incidents are also 
effective ways for an agency to improve its understanding of threats 
and the potential costs of security incidents, and doing so can 
pinpoint vulnerabilities that need to be addressed so that they are 
not exploited again. FISMA requires that each federal agency implement 
an information security program that includes procedures for 
detecting, reporting, and responding to security incidents. When 
incidents occur, agencies are to notify the federal information 
security incident center--the United States Computer Emergency 
Readiness Team (US-CERT). 

NARA has an incident response methodology and maintains an incident 
database with information about the categorization and analysis of 
incidents. However, NARA was not able to locate all of its weekly 
reports for incidents and did not consistently apply its criteria for 
incident categorization. According to the NARA incident response 
methodology, incidents involving the disclosures of personally 
identifiable information, even if the disclosure did not involve an IT 
system, should be categorized under "Investigation" (Category 6). 
While the records indicate that NARA reported these disclosures to US-
CERT, NARA did not list them as Category 6. 

NARA also categorized many of its computer security incidents 
inconsistently. Of 640 total incidents, 139 were classified as 
"Explained Anomaly" (Category 7). According to the NARA incident 
response methodology, this category is usually reserved for false 
positives and other explained anomalies. However, NARA classified a 
number of incidents in this category, even when the incident was not a 
false positive or could have been placed into another category. For 
example, NARA experienced site-redirection events--where a user was 
unwittingly directed to a malicious Web site while trying to access a 
legitimate site. This is a form of social engineering, which is 
categorized in the NARA incident response methodology under a separate 
category (Category 5). In addition, incidents where encrypted laptops 
were stolen were included in the "Explained Anomaly" category, though 
the NARA incident response methodology indicates that they should have 
been placed in Category 1, which indicates that unauthorized access 
may have occurred. 

NARA policy requires that staff be assigned and trained for the 
incident response team. While NARA tracks information security 
incidents and their resolution, it has not formally tracked training 
held for incident response. NARA officials have stated that they are 
in the process of formalizing this training program. Without ensuring 
that incident response personnel have received appropriate training, 
NARA's ability to implement security measures effectively could be 
limited. Further, without categorizing incidents appropriately, NARA's 
ability to analyze incidents for follow-on actions could be 
diminished, and corrective actions for protecting agency resources may 
not be taken. 

Contingency Plans Were Developed for Most Systems: 

Contingency planning is a critical component of information 
protection. If normal operations are interrupted, network managers 
must be able to detect, mitigate, and recover from service disruptions 
while preserving access to vital information. Therefore, a contingency 
plan details emergency response, backup operations, and disaster 
recovery for information systems. It is important that these plans be 
clearly documented, communicated to potentially affected staff, 
updated to reflect current operations, and regularly tested. Moreover, 
if contingency planning controls are inadequate, even relatively minor 
interruptions can result in lost or incorrectly processed data, which 
can lead to financial losses, expensive recovery efforts, and 
inaccurate or incomplete information. 

FISMA requires each agency to develop, document, and implement plans 
and procedures to ensure continuity of operations for information 
systems that support the agency's operations and assets. Both NIST and 
NARA require that contingency plans be developed and tested for 
information systems. 

NARA developed contingency plans for 9 of the 10 systems we reviewed. 
Further, NARA had tested each of the contingency plans. However, a 
contingency plan was not developed for a system key to tracking 
physical records. NARA identified this weakness, but had not corrected 
it during the time of our review. Although all the systems in our 
review were tested for contingencies, NARA has less assurance that it 
can appropriately recover a key system in a timely manner from certain 
service disruptions. 

Conclusions: 

NARA has taken important steps in implementing controls to protect the 
information and systems that support its mission. However, significant 
weaknesses in access controls and other information security controls 
exist that impair its ability to ensure the confidentiality, 
integrity, and availability of the information and systems supporting 
its mission. The key reason for many of the weaknesses is that NARA 
has not yet fully implemented elements of its information security 
program to ensure that effective controls are established and 
maintained. Effective implementation of such a program includes 
establishing appropriate policies and procedures, providing security 
awareness training, responding to incidents, and ensuring continuity 
of operations. Ensuring that NARA implements key information security 
practices and controls also requires effective management oversight 
and monitoring. However, until NARA implements these controls, it will 
have limited assurance that its information and information systems 
are adequately protected against unauthorized access, disclosure, 
modification, or loss. 

Recommendations for Executive Action: 

To help establish an effective information security program for NARA's 
information and information systems, we recommend that the Archivist 
of the United States take the following 11 actions: 

* Update NARA's system documentation and inventory to reflect accurate 
FIPS 199 categorizations. 

* Conduct physical security risk assessments of NARA's buildings and 
facilities based on facility-level and federal requirements. 

* Revise NARA's IT security methodologies, including those for access 
controls, certification and accreditation, and contingency planning, 
to include NIST's minimum system control requirements. 

* Include inventory information and roles and responsibilities 
assignments in system security plans. 

* Improve NARA's training process to ensure that all required 
personnel meet security awareness training requirements. 

* Implement a process that ensures all required NARA personnel with 
significant security responsibilities meet specialized training 
requirements. 

* Test management, operational, and technical controls for all systems 
at least annually. 

* Conduct certification testing when authorizing systems to operate. 

* Update remedial action plans in a timely manner and include required 
resources necessary for mitigating weaknesses, scheduled completion 
dates, milestones, and how weaknesses were identified. 

* Improve the incident tracking process to ensure that incidents are 
appropriately categorized and that personnel responsible for tracking 
and reporting incidents are trained. 

* Develop a contingency plan for the system that tracks physical 
records. 

In a separate upcoming report with limited distribution, we plan to 
make 213 recommendations to enhance NARA's access controls to address 
the 142 weaknesses identified during this audit. 

Agency Comments and Our Evaluation: 

In providing written comments on a draft of this report (reprinted in 
app. III), the Archivist of the United States stated that he was 
pleased with the positive recognition of NARA's efforts and that he 
generally concurred with our recommendations. NARA also provided 
technical comments, which we have incorporated as appropriate. 

In addition, the Archivist in his comments disagreed with three of the 
report's findings. First, he disagreed that NARA's risk assessments in 
its systems inventory were incorrectly applied. However, our finding 
does not state that the risk assessments were incorrectly applied. 
Rather, as we discuss in the report, NARA system documentation and 
system inventories do not consistently reflect the FIPS 199 impact 
levels of its systems. These inconsistencies may reduce NARA's 
assurance that adequate controls are in place to protect its 
information and information systems. Thus, we continue to believe our 
finding is appropriate. 

Secondly, the Archivist disagreed that NARA policies and procedures 
were not always consistent with NIST guidance. As we discuss in our 
report, NIST states that an agency must first determine the security 
category of its information systems and then apply the appropriately 
tailored set of baseline security controls. However, NARA's policy 
prescribed controls based on the individual security objectives of 
confidentiality, integrity, and availability instead of applying 
controls based on a prior determination of the system's impact. We 
believe that without first identifying the impact of the system, 
NARA's policy may not provide the information needed to ensure that 
appropriate systems controls are selected that protect its information 
systems. Thus, we continue to believe our finding is valid. 

Lastly, the Archivist disagreed that the information owner role must 
be identified in each system security plan. However, NARA's policy as 
discussed in the report outlines key individual roles and 
responsibilities, including the information owner, which should be 
assigned for each system. By not clearly and consistently assigning 
these roles, NARA increases the risk that critical information may not 
be available to those responsible for implementing system security 
plans. Thus, we continue to believe our finding is valid. 

As we agreed with your office, unless you publicly announce the 
contents of this report earlier, we plan no further distribution of it 
until 30 days from the date of this letter. At that time, we will send 
copies of this report to interested congressional committees and to 
the Archivist of the United States. In addition, this report will be 
available at no charge on the GAO Web site at [hyperlink, 
http://www.gao.gov]. 

If you have any questions about this report, please contact Gregory C. 
Wilshusen at (202) 512-6244 or Dr. Nabajyoti Barkakati at (202) 512- 
4499. We can also be reached by e-mail at wilshuseng@gao.gov or 
barkakatin@gao.gov. Contact points for our Offices of Congressional 
Relations and Public Affairs may be found on the last page of this 
report. Key contributors to this report are listed in appendix IV. 

Sincerely yours, 

Signed by: 

Gregory C. Wilshusen: 
Director, Information Security Issues: 

Signed by: 

Dr. Nabajyoti Barkakati: 
Chief Technologist: 

[End of section] 

Appendix I: Objective, Scope, and Methodology: 

The objective of our review was to determine whether the National 
Archives and Records Administration (NARA) has effectively implemented 
appropriate information security controls to protect the 
confidentiality, integrity, and availability of the information and 
systems that support its mission. 

To determine the effectiveness of security controls, we gained an 
understanding of the overall network control environment, identified 
interconnectivity and control points, and examined controls for NARA's 
networks and facilities. Using our Federal Information System Controls 
Audit Manual[Footnote 16] which contains guidance for reviewing 
information system controls that affect the confidentiality, 
integrity, and availability of computerized information; National 
Security Agency guidance; National Institute of Standards and 
Technology (NIST) standards and guidance; and NARA's policies, 
procedures, practices, and standards, we evaluated these controls by: 

* reviewing network access paths to determine if boundaries were 
adequately protected; 

* reviewing the complexity and expiration of password settings to 
determine if password management was enforced; 

* analyzing users' system authorizations to determine whether they had 
more permission than necessary to perform their assigned functions; 

* observing methods for providing secure data transmissions across the 
network to determine whether sensitive data were being encrypted; 

* reviewing software security settings to determine if modifications 
of sensitive or critical system resources were monitored and logged; 

* observing physical access controls over unclassified and classified 
areas to determine if computer facilities and resources were being 
protected from espionage, sabotage, damage, and theft; 

* examining configuration settings and access controls for routers, 
network management servers, switches, and firewalls; 

* inspecting key servers and workstations to determine if critical 
patches had been installed and/or were up to date; 

* reviewing media handling policy, procedures, and equipment to 
determine if sensitive data were cleared from digital media before 
media were disposed of or reused; 

* reviewing nondisclosure agreements at select locations to determine 
if they are required for personnel with access to sensitive 
information; and: 

* examining access roles and responsibilities to determine whether 
incompatible functions were segregated among different individuals. 

Using the requirements identified by the Federal Information Security 
Management Act of 2002 (FISMA), which establishes key elements of an 
agencywide information security program, and associated NIST 
guidelines and NARA requirements, we evaluated the effectiveness of 
NARA's implementation of its security program by: 

* reviewing NARA's risk assessment process and risk assessments for 10 
systems to determine whether risks and threats were documented 
consistent with federal guidance; 

* analyzing NARA policies, procedures, practices, and standards to 
determine their effectiveness in providing guidance to personnel 
responsible for securing information and information systems; 

* analyzing security plans for 10 out of 43 systems to determine if 
management, operational, and technical controls were in place or 
planned and whether security plans reflected the current environment; 

* examining the security awareness training process for employees and 
contractors to determine if they received training prior to system 
access; 

* examining training records for personnel with significant 
responsibilities to determine if they received training commensurate 
with those responsibilities; 

* analyzing NARA's procedures and results for testing and evaluating 
security controls to determine whether management, operational, and 
technical controls were sufficiently tested at least annually and 
based on risk; 

* evaluating NARA's process to correct weaknesses and determining 
whether remedial action plans complied with federal guidance; 

* reviewing incident detection and handling policies, procedures, and 
reports to determine the effectiveness of the incident handling 
program; 

* examining contingency plans for 10 systems to determine whether 
those plans were developed and tested; and: 

* reviewing three IT contracts to determine if security requirements 
were included. 

We also discussed with key security representatives and management 
officials whether information security controls were in place, 
adequately designed, and operating effectively. 

To establish the reliability of NARA's computer-processed data we 
performed an assessment. We evaluated the materiality of the data to 
our audit objectives and proceeded to assess the data by various means 
including: reviewing related documents, interviewing knowledgeable 
agency officials, and reviewing internal controls. Through a 
combination of methods we concluded that the data were sufficiently 
reliable for the purposes of our work. 

We conducted this performance audit from December 2009 to October 2010 
in accordance with generally accepted government auditing standards. 
Those standards require that we plan and perform the audit to obtain 
sufficient, appropriate evidence to provide a reasonable basis for our 
findings and conclusions based on our audit objective. We believe that 
the evidence obtained provides a reasonable basis for our findings and 
conclusions based on our audit objective. 

[End of section] 

Appendix II: NARA Organizational Chart: 

[Refer to PDF for image: organizational chart] 

Top level: 

Archivist of the United States: 
* Deputy Archivist of the United States; 
* Chief of Staff. 

Second level: 

Staff offices: 
* Congressional Affairs Staff; 
* General Counsel; 
* EEO and Diversity Programs; 
* Public Affairs and Communications Staff; 
* Policy and Planning Staff. 

Independent offices that report directly to the Archivist: 
* Information Security Oversight Office; 
* National Historical Publications and Records Commission; 
* Office of Government Information Services; 
* Office of the Inspector General. 

Major offices: 
* Office of Records Services, Washington, D.C. 
* Office of Regional Records Services; 
* Office of Presidential Libraries; 
* Office of the Federal Register; 
* Office of Information Services; 
* Office of Administration. 

Source: NARA. 

[End of section] 

Appendix III: Comments from the National Archives and Records 
Administration: 

National Archives: 
Archivist of the United States: 
David S. Ferriero: 
National Archives and Records Administration: 
700 Pennsylvania Avenue, NW:
Washington, DC 20408-0001: 
[hyperlink, http://www.archives.gov] 

Via messenger: 

October 5, 2010: 

Gregory C. Wilshusen: 
Director, Information Security Issues: 
United States Government Accountability Office: 
44 G Street, NW: 
Washington, DC 20548: 

Dear Mr. Wilshusen: 

Thank you for the opportunity to review and comment on the draft 
report entitled Information Security: National Archives and Records 
Administration Needs to Implement Key Program Elements and Controls. 
We are pleased to note the positive recognition of our efforts by the 
audit staff for this engagement. We also appreciate their willingness to
work with us on fine tuning some of the language in the draft report, 
specifically regarding technical nuances. Finally, we agree that more 
action is needed. 

We disagree with certain findings in this report, specifically: 

* that our risk assessments in systems inventory are incorrectly 
applied (see page 26); 

* that our policies and procedures are not always consistent with NIST 
guidance (see page 27); and; 

* that the "owner role" must be identified in each system security 
plan (see page 31). 

In each case, we believe that we have demonstrated good faith efforts 
to keep these current, and acknowledge that sometimes things get 
missed. Nonetheless, we generally concur with each of the eleven 
recommendations. 

Many changes are underway at NARA, including a staff reorganization 
that will help us more effectively address these and other challenges 
we face. We will create an action plan for internal use and provide 
semi-annual updates on our progress. 

If you have questions regarding this information, please contact Mary 
Drak by email at mary.drak@nara.gov or by phone at 301-837-1668. 

Signed by: 

David S. Ferriero: 
Archivist of the United States: 

[End of section] 

Appendix IV: GAO Contacts and Staff Acknowledgments: 

GAO Contacts: 

Gregory C. Wilshusen, (202) 512-6244, wilshuseng@gao.gov. 
Dr. Nabajyoti Barkakati, (202) 512-4499, barkakatin@gao.gov. 

Staff Acknowledgments: 

In addition to the individuals named above, Edward Alexander, Lon 
Chin, West Coile, Anjalique Lawrence, and Chris Warweg (Assistant 
Directors); Gary Austin; Angela Bell; Larry Crosland; Saar Dagani; 
Kirk Daubenspeck; Denise Fitzpatrick; Fatima Jahan; Mary Marshall; 
Sean Mays; Lee McCracken; Jason Porter; Michael Redfern; Richard 
Solaski; and Jayne Wilson made key contributions to this report. 

[End of section] 

Footnotes: 

[1] GAO, Electronic Records Archives: Status Update on the National 
Archives and Records Administration's Fiscal Year 2010 Expenditure 
Plan, [hyperlink, http://www.gao.gov/products/GAO-10-657] (Washington, 
D.C.: June 11, 2010). 

[2] FISMA was enacted as title III, E-Government Act of 2002, Pub. L. 
No.107-347, 116 Stat. 2899, 2946 (Dec. 17, 2002). 

[3] Root accounts have special privileges beyond normal accounts for 
access to files and programs. Allowing remote login to root accounts 
decreases individual accountability because the root account is not 
tied to a specific user. 

[4] Source routing is a feature that allows a packet to specify its 
own route, which can be helpful in several kinds of attack and should 
be disabled. 

[5] FIPS 140-2 specifies the security requirements that will be 
satisfied by a cryptographic module utilized within a security system 
protecting sensitive but unclassified information (hereafter referred 
to as sensitive information). 

[6] A degausser is a device that generates a magnetic field used to 
sanitize magnetic media. 

[7] The process of removing sensitive information from computer media 
is often referred to as sanitization. It includes removing all labels, 
markings, and activity logs. NIST Guidelines for Media Sanitization, 
Special Publication 800-88 (Gaithersburg, Md., September 2006), 
provides guidance on appropriate sanitization equipment, techniques, 
and procedures. 

[8] NIST Federal Information Processing Standards Publication 199, 
Standards for Security Categorization of Federal Information and 
Information Systems, defines three impact levels where the loss of 
confidentiality, integrity, or availability could be expected to have 
a limited adverse effect (low), a serious adverse effect (moderate), 
or a severe or catastrophic adverse effect (high) on organizational 
operations, organizational assets, or individuals. 

[9] NIST, Standards for Security Categorization of Federal Information 
and Information Systems, FIPS Publication 199 (Gaithersburg, Md., 
February 2004). 

[10] According to the Federal Interagency Security Committee Standard 
"Facility Security Level Determinations for Federal Facilities," 
federal organizations are required to perform risk assessments at 
least every 3 to 5 years, depending on the level of the facility. 
Facilities visited at NARA were rated at a level requiring a frequency 
of at least 3 years. 

[11] NIST, Recommended Security Controls for Federal Information 
Systems and Organizations, Special Publication 800-53, Revision 3 
(Gaithersburg, Md., August 2009). 

[12] OMB, Management of Federal Information Resources, Circular No. A- 
130 (Nov. 28, 2000). 

[13] NIST, Recommended Security Controls for Federal Information 
Systems and Organizations, Special Publication 800-53, Revision 3 
(Gaithersburg, Md., August 2009). 

[14] NARANET has system security plans for four subcomponents: (1) the 
General Support System (GSS) Application Servers; (2) desktops; (3) 
enterprise architecture wireless; and (4) GSS file, print, and e-mail. 

[15] 4,536 is the total number of employees and contractors who are 
required to complete the security awareness training. 

[16] GAO, Federal Information System Controls Audit Manual (FISCAM), 
[hyperlink, http://www.gao.gov/products/GAO-09-232G] (Washington D.C.: 
February 2009). 

[End of section] 

GAO's Mission: 

The Government Accountability Office, the audit, evaluation and 
investigative arm of Congress, exists to support Congress in meeting 
its constitutional responsibilities and to help improve the performance 
and accountability of the federal government for the American people. 
GAO examines the use of public funds; evaluates federal programs and 
policies; and provides analyses, recommendations, and other assistance 
to help Congress make informed oversight, policy, and funding 
decisions. GAO's commitment to good government is reflected in its core 
values of accountability, integrity, and reliability. 

Obtaining Copies of GAO Reports and Testimony: 

The fastest and easiest way to obtain copies of GAO documents at no 
cost is through GAO's Web site [hyperlink, http://www.gao.gov]. Each 
weekday, GAO posts newly released reports, testimony, and 
correspondence on its Web site. To have GAO e-mail you a list of newly 
posted products every afternoon, go to [hyperlink, http://www.gao.gov] 
and select "E-mail Updates." 

Order by Phone: 

The price of each GAO publication reflects GAOís actual cost of
production and distribution and depends on the number of pages in the
publication and whether the publication is printed in color or black and
white. Pricing and ordering information is posted on GAOís Web site, 
[hyperlink, http://www.gao.gov/ordering.htm]. 

Place orders by calling (202) 512-6000, toll free (866) 801-7077, or
TDD (202) 512-2537. 

Orders may be paid for using American Express, Discover Card,
MasterCard, Visa, check, or money order. Call for additional 
information. 

To Report Fraud, Waste, and Abuse in Federal Programs: 

Contact: 

Web site: [hyperlink, http://www.gao.gov/fraudnet/fraudnet.htm]: 
E-mail: fraudnet@gao.gov: 
Automated answering system: (800) 424-5454 or (202) 512-7470: 

Congressional Relations: 

Ralph Dawn, Managing Director, dawnr@gao.gov: 
(202) 512-4400: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7125: 
Washington, D.C. 20548: 

Public Affairs: 

Chuck Young, Managing Director, youngc1@gao.gov: 
(202) 512-4800: 
U.S. Government Accountability Office: 
441 G Street NW, Room 7149: 
Washington, D.C. 20548: