Policy Analysis----Security Policy of

Center for Information Technology of National Institutes of Health

School of Information and Library Science


 

Introduction:
This security policy is developed by Center for Information Technology of Nation Institutes of Health. It can be accessed through Internet at http://irm.cit.nih.gov/security/sec_policy.html.

Summary:
The Policy consists of five parts: Policy on Chain Letters, Policy on Passwords, Policy on Warning Banners, Remote Access Policy and Sanitization Policy. Each of them addresses a specific security issue. Following the policies, Security Guidelines, which are meant to provide more detailed information on how to comply with those policies, and links to federal regulations concerning security issues are also provided.

In summary:

Policy on Chain Letters emphasizes the prohibition of sending and forwarding chain letters using NIH network systems, briefly describes possible damages of chain letters, gives a detailed definition of chain letters, describes the responsibilities of supervisory personnel and employees, and states possible punishment for policy violation.

Policy on Passwords addresses the issue of password usage and management. It requires that every user should choose a password difficult to decipher and change password at least every 6 months. Since information system managers and administrative managers take extra roles in enforcing this policy, it requires system managers to configure the system properly to enforce the 6 month policy, and requires administrative managers to develop, post and enforce this policy following the guideline provided.

Policy on Warning Banners requires that "[e]employee"sign-on warning banners" must be posted at all logon points to Government computers and systems...". It justifies this policy by quoting Department of Justice recommendations and advice from the Office of Inspector General. It even gives an example of warning banners.

Remote Access Policy is actually a summary of The NIH Policy on Remote Access to the NIH Network (NIH Manual Chapter 26101-26-08). It addresses the responsibilities of Executive Officers or their designees in developing and implementing remote access program, defines who can have remote access to NIH network systems and how the expenses associated with remote access connections can be covered.

The core of Sanitization Policy is that "[b]efore any NIH-owned or managed hard disk or system containing a hard disk is transferred, surplused, or donated, it must be sanitized by reformatting the hard drive in a secure manner or by using an approved wipeout utility". It provides a step by step technical guideline on where sanitization programs can be found, and what actions should be taken under difference situation.

Criteria:
The following criteria will be used to assess this security policy:

  • Completeness: whether it contains some of the common elements of well-developed policies. According to Tudor (2001),a well-developed security policy normally contains "an introduction or background on why the policy is necessary, what management is trying to achieve through the establishment of the policy, the approval authority, the authors, references to other policies and regulations, compliance measures, consequences to violations, and date of policy". Although not every policy should contain the above elements, they provide a guideline to check where one of them is necessary but the policy fails to mention.
  • Readability: whether the policies are short enough to hold reader's patience or whether a digested form of policy is provided for long policies. Policies should be easy to read and understand. They should not contain too many technical jargons and quote too many legal statements.
  • Applicability: There should be enough guidance and information for users to follow. Contact information, help desk, tools availability, step by step guide lines are essential in assisting users to comply the policy.
  • Clarity of language: policies should be unambiguous. Key terms should be clearly defined.

Analysis:

Completeness: The set of policies have different degrees of completeness. It might be that they are written by several authors. Policy on Chain Letters can be taken as a good example. It answers the following questions:

  • why the policy is necessary: "The proliferation of chain letters and other unauthorized "mass mailings" causes network congestion and impedes the routing of legitimate e-mail messages."
  • what to achieve: "NIH e-mail and Internet services are for government use in support of the NIH mission."
  • the authors: Acting Director, Office of Information Resources Management (OIRM)
  • References to other policies and regulations: there are two paragraphs that are especially devoted to Other Prohibited Uses and Appropriate Use of Government Resources
  • compliance measures: If you receive an e-mail chain letter, you should simply delete it. If you also wish to report it, contact your information systems security officer (see list of contacts on the OIRM Security Page). Other than forwarding the message--for reporting purposes--to your information systems security officer, you should never forward an e-mail chain letter to other individuals.
  • consequence to violations:"NIH employees and authorized users who use NIH e-mail, Internet services, and other information resources in a manner prohibited by the DHHS Standards of Conduct are subject to disciplinary action."
  • date of policy: July 08, 1997

    However for Policy on Remote Access, important elements that are missing or not clear include why the policy is necessary and what management is trying to achieve through this policy. There is no stated consequence of violations either.

    Readability: Generally, the policies are short, concise, and most of them use plain languages in describing technical quinces. Take Policy on Password as an example, it separates its audience into three parts--all users, System managers and IC managers, and states each group's responsibilities separately. For an ordinary user, he/she may just look at the part for users without bothering about the other parts. There is only one or two sentences in each part, and language is clear and easy to understand, such as "[c]hange passwords at least every 6 months", "[c]onfigure servers and systems to require that users change passwords every 6 months." The Policy on Remote Access also provides good summary of the longer NIH Policy on Remote Access to the NIH Network (NIH Manual Chapter 26101-26-08) to help users understand the core elements.

    Applicability: The set of policies are quite good at providing relevance links and guidelines for users. On the security policy page, immediately following the five policies are fourteen links for compliance guidance. Inside of each policy, contact information and help desk information are normally provided. For example the Sanitization Policy didn't fail to provide a contact list for help--"Consult with your Information Systems Security Officer (a roster is located at http://irm.cit.nih.gov/nihsecurity/scroster.html) prior to getting rid of any computer equipment".

  • Clarity of language: The policies reflects different writing styles. Some policies are very clear, while others are more casual. Take Policy on Chain Letters again as an example. Immediately after the first paragraph, the author(s) gives the definition of Chain Letters as:

    "A chain letter e-mail message, sent to several addressees, typically requests each recipient to send copies to additional individuals; as a result, its circulation increases geometrically. Chain letters generally have a similar pattern, consisting of three recognizable parts: (1) a hook, which catches the reader's interest; (2) a threat, which warns of negative consequences if the chain is not maintained; and (3) a request, which asks that the message be forwarded to multiple addressees. Chain letters may claim a variety of warnings (e.g., personal misfortune) if the instruction to forward multiple messages is ignored. "

    If anyone has doubts on what a chain letter is, he/she should be clear by now. The author of Policy of Warning Banners fails to give the definition of warning banner, and places its emphasis on quoting what Department of Justice and Office of Inspector General would recommend on this issue. It's only after the policy gives an example of warning banner does the reader begin to understand what he/she is talking about.

    Recommendations:
    It is interesting to find that, although the five policies are grouped together under security policies, they are quite different in terms of writing style and quality. Some policy serves as a better example than the other. Policy on Chain Letters excels in completeness and clarity. Sanitization Policy is good at providing clear and detailed guidance to users, or applicability. Policy on Passwords is good in terms of readability. Policy on Warning Banners and Policy on Remote Access pursued a more casual way, but some important elements are missing.

    My recommendations are: first, set of policies should follow a similar style. Common elements, clear and short paragraphs make it easier for its targeted audience to quickly grasp the key points the policy wants to express. After all, policies are not casual readings, and needs some efforts to read through.

    Second, a straight forward, right-on-the-point style is preferred. Readers may not care about what Department of Justice or Office of Inspector General would recommend. A brief statement of why the policy is important and what the management wants from the reader concern the reader more.

    Third, Tudor (2001)'s list of common elements provides a good guidance on what should be covered in the policy. They are important elements as well, and should generally be covered in a well written policy. For example, although these policies are good at providing compliance guideline, but compliance measures and consequences of violation are only mentioned occasionally.

    References:

    Tudor, Jan Killmeyer. (2001). Information Security Architecture: an Integrated Approach to Security in the Organization. Auerbach: New York


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