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1,200 | rocery store experience.” The use of WIC vouchers to purchase food in grocery stores can cause confusion and delays for both the participant-shopper and the store clerk at the check-out counter. For example, Texas requires its WIC participants to buy the cheapest brand of milk, evaporated milk, and cheese available in the store. Texas also requires participants to buy the lowest-cost 46-ounce fluid or 12-ounce frozen fruit juices from an approved list of types (orange, grapefruit, orange/grapefruit, purple |
1,201 | grape, pineapple, orange/pineapple, and apple) and/or specific brands. In comparing the cost of WIC-approved items, participants must also consider such things as weekly store specials and cost per ounce in order to purchase the lowest-priced items. While these restrictions may lower the dollar amount that the state pays for WIC foods, it may also make food selections more confusing for participants. According to Texas WIC officials, participants and cashiers often have difficulty determining which products |
1,202 | have the lowest price. Consequently, a delay in the check-out process may result in unwanted attention for the WIC participant. Finally, more than half of the directors indicated that a major factor limiting participation is that working women are not aware that they are eligible to participate in WIC. Furthermore, local agency officials in California and Texas said that WIC participants who were not working when they entered the program but who later go to work often assume that they are then no longer el |
1,203 | igible for WIC and therefore drop out of the program. In September 1997, we reported that the states have used a variety of initiatives to control WIC costs. According to the WIC agency directors in the 50 states and the District of Columbia we surveyed, two practices in particular are saving millions of dollars. These two practices are (1) contracting with manufacturers to obtain rebates on WIC foods in addition to infant formula and (2) limiting authorized food selections by, for example, requiring partic |
1,204 | ipants to select brands of foods that have the lowest cost. With respect to rebates, nine state agencies received $6.2 million in rebates in fiscal year 1996 through individual or multistate contracts for two WIC-approved foods—infant cereal and/or infant fruit juices. Four of these state agencies and seven other state agencies—a total of 11 states—reported that they were considering, or were in the process of, expanding their use of rebates to foods other than infant formula. In May 1997, Delaware, one of |
1,205 | the 11 states, joined the District of Columbia, Maryland, and West Virginia in a multistate rebate contract for infant cereal and juices. Another state, California, was the first state to expand its rebate program in March 1997 to include adult juices. California spends about $65 million annually on adult juice purchases. California’s WIC director told us that the state expects to collect about $12 million in annual rebates on the adult juices, thereby allowing approximately 30,000 more people to participat |
1,206 | e in the program each month. With respect to placing limits on food selections, all of the 48 state WIC directors responding to our survey reported that their agencies imposed limits on one or more of the food items eligible for program reimbursement. The states may specify certain brands; limit certain types of foods, such as allowing the purchase of block but not sliced cheese; restrict container sizes; and require the selection of only the lowest-cost brands. However, some types of restrictions are more |
1,207 | widely used than others. For example, 47 WIC directors reported that their states’ participants are allowed to choose only certain container or package sizes of one or more food items, but only 20 directors reported that their states require participants to purchase the lowest-cost brand for one or more food items. While all states have one or more food selection restrictions, 17 of the 48 WIC directors responding to our questionnaire reported that their states are considering the use of additional limits o |
1,208 | n food selection to contain or reduce WIC costs. Separately or in conjunction with measures to contain food costs, we found that 39 state agencies have placed restrictions on their authorized retail outlets (food stores and pharmacies allowed to redeem WIC vouchers—commonly referred to as vendors) to hold down costs. For example, the prices for WIC food items charged by WIC vendors in Texas must not exceed by more than 8 percent the average prices charged by vendors doing a comparable dollar volume of busin |
1,209 | ess in the same area. Once selected, authorized WIC vendors must maintain competitive prices. According to Texas WIC officials, the state does not limit the number of vendors that can participate in WIC. However, Texas’ selection criteria for approving a vendor excludes many stores from the program. In addition, 18 WIC directors reported that their states restrict the number of vendors allowed to participate in the program by using ratios of participants to vendors. For example, Delaware used a ratio of 200 |
1,210 | participants per store in fiscal year 1997 to determine the total number of vendors that could participate in the program in each WIC service area. By limiting the number of vendors, states can more frequently monitor vendors and conduct compliance investigations to detect and remove vendors from the program who commit fraud or other serious program violations, according to federal and state WIC officials. A July 1995 report by USDA’s Office of Inspector General found that the annual loss to WIC as a resul |
1,211 | t of vendor fraud in one state could exceed $3 million. The WIC directors in 2 of the 39 states that reported limiting the number of vendors indicated that they are planning to introduce additional vendor initiatives, such as selecting vendors on the basis of competitive food pricing. We also found that opportunities exist to substantially lower the cost of special infant formula. Special formula, unlike the regular formula provided by WIC, is provided to infants with special dietary needs or medical condit |
1,212 | ions. Cost savings may be achieved if the states purchase special infant formula at wholesale instead of retail prices. The monthly retail cost of these special formulas can be high—ranging in one state we surveyed from $540 to $900 for each infant. These high costs occur in part because vendors’ retail prices are much higher than the wholesale cost. Twenty-one states avoid paying retail prices by purchasing the special formula directly from the manufacturers and distributing it to participants. For example |
1,213 | , Pennsylvania turned to the direct purchase of special infant formula to address the lack of availability and high cost of vendor-provided formulas. It established a central distribution warehouse for special formulas in August 1996 to serve the less than 1 percent of WIC infants in the state—about 400—who needed special formula in fiscal year 1996. The program is expected to save about $100,000 annually. Additional savings may be possible if these 21 states are able to reduce or eliminate the authorizatio |
1,214 | n and monitoring costs of retail vendors and pharmacies that distribute only special infant formula. For example, by establishing its own central distribution warehouse, Pennsylvania plans to remove over 200 pharmacies from the program, resulting in significant administrative cost savings, according to the state WIC director. While the use of these cost containment practices could be expanded, our work found that a number of obstacles may discourage the states from adopting or expanding these practices. The |
1,215 | se obstacles include problems that states have with existing program restrictions on how additional funds made available through cost containment initiatives can be used and resistance from the retail community when states attempt to establish selection requirements or limit retail stores participating in the program. First, FNS policy requires that during the grant year, any savings from cost containment accrue to the food portion of the WIC grant, thereby allowing the states to provide food benefits to ad |
1,216 | ditional WIC applicants. None of the cost savings are automatically available to the states for support services, such as staffing, clinic facilities, voucher issuance sites, outreach, and other activities that are funded by WIC’s NSA (Nutrition Services and Administration) grants. These various support activities are needed to increase participation in the program, according to WIC directors. As a result, the states may not be able to serve more eligible persons or they may have to carry a substantial port |
1,217 | ion of the program’s support costs until the federal NSA grant is adjusted for the increased participation level—a process that can take up to 2 years, according to the National Association of WIC Directors. FNS officials pointed out that provisions in the federal regulations allow the states that have increased participation to use a limited amount of their food grant funds for support activities. However, some states may be reluctant to use this option because, as one director told us, doing so may be per |
1,218 | ceived as taking food away from babies. FNS and some state WIC officials told us that limiting the number of vendors in the program is an important aspect of containing WIC costs. However, they told us the retail community does not favor limits on the number of vendors that qualify to participate. Instead, the retail community favors the easing of restrictions on vendor eligibility thereby allowing more vendors that qualify to accept WIC vouchers. According to FNS officials, the amount that WIC spends for f |
1,219 | ood would be substantially higher if stores with higher prices were authorized to participate in the program. To encourage the further implementation of WIC cost containment practices, we recommended in our September 1997 report that FNS work with the states to identify and implement strategies to reduce or eliminate such obstacles. These strategies could include modifying the policies and procedures that allow the states to use cost containment savings for the program’s support services and establishing re |
1,220 | gulatory guidelines for selecting vendors to participate in the program. FNS concurred with our findings and recommendations. We will continue to monitor the agency’s progress made in implementing strategies to reduce or eliminate obstacles to cost containment. Our survey also collected information on the practices that the states are using to ensure that program participants meet the program’s income and residency requirements. The states’ requirements for obtaining income documentation vary. Of the 48 WIC |
1,221 | directors responding to our survey, 32 reported that their state agencies generally require applicants to provide documentation of income eligibility; 14 reported that their states did not require documentation and allowed applicants to self-declare their income; and 2 reported that income documentation procedures are determined by local WIC agencies. Of the 32 states requiring income documentation, 30 reported that their documentation requirement could be waived under certain conditions. Our review of sta |
1,222 | te income documentation polices found that waiving an income documentation requirement can be routine. For example, we found that some states requiring documentation of income will waive the requirement and permit self-declaration of income if the applicants do not bring income documents to their certification meeting. While existing federal regulations allow the states to establish their own income documentation requirements for applicants, we are concerned that basing income eligibility on the applicants’ |
1,223 | self-declarations of income may permit ineligible applicants to participate in WIC. However, the extent of this problem is unknown because there has not been a recent study of the number of program participants who are not eligible because of income. Information from a study that FNS has begun should enable that agency to determine whether changes in states’ requirements for income documentation are needed. Regarding residency requirements, we found that some states have not been requiring proof of residen |
1,224 | cy and personal identification for program certification, as required by federal regulations. In our September 1997 report, we recommended that FNS take the necessary steps to ensure that state agencies require participants to provide identification and evidence that they reside in the states where they receive benefits. In February 1998, FNS issued a draft policy memorandum to its regional offices that is intended to stress the continuing importance of participant identification, residency, and income requ |
1,225 | irements and procedures to ensure integrity in the certification and food instrument issuance processes. Also, at the request of FNS, we presented our review’s findings and recommendations at the EBT and Program Integrity Conference jointly sponsored by the National Association of WIC Directors and FNS in December 1997. The conference highlighted the need to reduce ineligible participation and explored improved strategies to validate participants’ income and residency eligibility. FNS requires the states to |
1,226 | operate a rebate program for infant formula. By negotiating rebates with manufacturers of infant formula purchased through WIC, the states greatly reduce their average per person food costs so that more people can be served. At the request of the Chairman of the House Budget Committee, we are currently reviewing the impacts that these rebates have had on non-WIC consumers of infant formula. Specifically, we will report on (1) how prices in the infant formula market changed for non-WIC purchasers and WIC ag |
1,227 | encies after the introduction of sole-source rebates, (2) whether there is any evidence indicating that non-WIC purchasers of infant formula subsidized WIC purchases through the prices they paid, and (3) whether the significant cost savings for WIC agencies under sole source rebates for infant formula have implications for the use of rebates for other WIC products. Thank you again for the opportunity to appear before you today. We would be pleased to respond to any questions you may have. The first copy of |
1,228 | each GAO report and testimony is free. Additional copies are $2 each. Orders should be sent to the following address, accompanied by a check or money order made out to the Superintendent of Documents, when necessary. VISA and MasterCard credit cards are accepted, also. Orders for 100 or more copies to be mailed to a single address are discounted 25 percent. U.S. General Accounting Office P.O. Box 37050 Washington, DC 20013 Room 1100 700 4th St. NW (corner of 4th and G Sts. NW) U.S. General Accounting Office |
1,229 | Washington, DC Orders may also be placed by calling (202) 512-6000 or by using fax number (202) 512-6061, or TDD (202) 512-2537. Each day, GAO issues a list of newly available reports and testimony. To receive facsimile copies of the daily list or any list from the past 30 days, please call (202) 512-6000 using a touchtone phone. A recorded menu will provide information on how to obtain these lists. |
1,230 | Since the early 1990s, increasing computer interconnectivity—most notably growth in the use of the Internet—has revolutionized the way that our government, our nation, and much of the world communicate and conduct business. The benefits have been enormous, but without proper safeguards in the form of appropriate information security, this widespread interconnectivity also poses significant risks to the government’s computer systems and the critical operations and infrastructures they support. In prior revie |
1,231 | ws we have repeatedly identified weaknesses in almost all areas of information security controls at major federal agencies, including VA, and we have identified information security as a high risk area across the federal government since 1997. In July 2005, we reported that pervasive weaknesses in the 24 major agencies’ information security policies and practices threatened the integrity, confidentiality, and availability of federal information and information systems. As we reported, although federal agenc |
1,232 | ies showed improvement in addressing information security, they also continued to have significant control weaknesses that put federal operations and assets at risk of inadvertent or deliberate misuse, financial information at risk of unauthorized modification or destruction, sensitive information at risk of inappropriate disclosure, and critical operations at risk of disruption. These weaknesses existed primarily because agencies had not yet fully implemented strong information security programs, as requir |
1,233 | ed by the Federal Information Security Management Act (FISMA). The significance of these weaknesses led us to conclude in the audit of the federal government’s fiscal year 2005 financial statements that information security was a material weakness. Our audits also identified instances of similar types of weaknesses in nonfinancial systems. Weaknesses continued to be reported in each of the major areas of general controls: that is, the policies, procedures, and technical controls that apply to all or a large |
1,234 | segment of an entity’s information systems and help ensure their proper operation. To fully understand the significance of the weaknesses we identified, it is necessary to link them to the risks they present to federal operations and assets. Virtually all federal operations are supported by automated systems and electronic data, without which agencies would find it difficult, if not impossible, to carry out their missions and account for their resources. The following examples show the broad array of feder |
1,235 | al operations and assets placed at risk by information security weaknesses: ● Resources, such as federal payments and collections, could be lost or stolen. ● Computer resources could be used for unauthorized purposes or to launch attacks on others. ● Personal information, such as taxpayer data, social security records, and medical records, and proprietary business information could be inappropriately disclosed, browsed, or copied for purposes of identity theft, industrial espionage, or other types of crime. |
1,236 | ● Critical operations, such as those supporting national defense and emergency services, could be disrupted. ● Data could be modified or destroyed for purposes of fraud, theft of assets, or disruption. ● Agency missions could be undermined by embarrassing incidents that result in diminished confidence in their ability to conduct operations and fulfill their fiduciary responsibilities. The potential disclosure of personal information raise identity theft and privacy concerns. Identity theft generally involv |
1,237 | es the fraudulent use of another person’s identifying information— such as Social Security number, date of birth, or mother’s maiden name—to establish credit, run up debt, or take over existing financial accounts. According to identity theft experts, individuals whose identities have been stolen can spend months or years and thousands of dollars clearing their names. Some individuals have lost job opportunities, been refused loans, or even been arrested fo crimes they did not commit as a result of identity |
1,238 | theft. The Feder Trade Commission (FTC) reported in 2005 that identity theft represented about 40 percent of all the consumer fraud complaints it received during each of the last 3 calendar years. Beyond the serious issues surrounding identity theft, the unauthorized disclosure of personal information also represents a breach of individuals’ privacy rights to have control over their own information and to be aware of who has access to this information. Federal agencies are subject to security and privacy la |
1,239 | ws aimed in part at preventing security breaches, including breaches that could enable identity theft. FISMA is the primary l federal government; it also addresses the protection of personal n information in the context of securing federal agency informatio r and information systems. The act defines federal requirements fo securing information and information systems that support federalaw governing information security in the agency operations and assets. Under FISMA, agencies are requiredto provide suffic |
1,240 | ient safeguards to cost-effectively protect their information and information systems from unauthorized access, use disclosure, disruption, modification, or destruction, including controls necessary to preserve authorized restrictions on access and disclosure (and thus to protect personal privacy, among other things). The act requires each agency to develop, document, and implement an agencywide information security program to provide , security for the information and information systems that support the o |
1,241 | perations and assets of the agency, including those provided or managed by another agency, contractor, or other source. FISMA describes a comprehensive information security pr including the following elements: periodic assessments of the risk an result from the unauthorized access, use, disclosure, disruption, modification, or destruction of information or information systems; d magnitude of harm that could risk-based policies and procedures that cost-effectively reduce ris to an acceptable level and ensure |
1,242 | that security is addressed throughout the life cycle of each information system; security awareness training for agency personnel, including contractors and other users of information systems th operations and assets of the agency; periodic testing and evaluation of the effectiveness of information security policies, procedures, and practices; ● a process for planning, implementing, evaluating, and documentingremedial action to address any deficiencies th and milestones; and procedures for detecting, repor |
1,243 | ting, and responding to security incidents. In particula agencies evaluate the associated risk according to three categories: (1) confidentiality, which is the risk associated with unauthorized disclosure of the information; (2) integrity, the risk of unauthorized modification or destruction of the information; and (3) availability, which is the risk of disruption of access to or use of information. Thus, each agency should assess the risk associated with personal data held by the agency and develop appropr |
1,244 | iate protections. r, FISMA requires that for any information they hold, The agency can use this risk assessment to determine the appropriate controls (operational, technical, and managerial) th will reduce the risk to an acceptably low level. For exampl agency assesses the confidentiality risk of the personal information as high, the agency could create control mechanisms to help prote ct the data from unauthorized disclosure. Besides appropriate policies,at e, if an these controls would include access cont |
1,245 | rols and monitoring systems: Access con confidentiality of information. Organizations use these controls to grant employees the authority to read or modify only the information the employees need to perform their duties. In addition access controls can limit the activities that an employee c perform on data. For example, an employee may be given the right to read data, but not to modify or copy it. Assignment of right s and permissions must be carefully considered to avoid giving users unnecessary access to |
1,246 | sensitive files and directories. trols are key technical controls to protect the To ensure that controls are, in fact, implemented and that no violations have occurred, agencies need to monitor compliance with security policies and investigate security violations. It is crucial to determine what, when, and by whom specific actions are taken on a system. Organizations accomplish this by implementing system or security software that provides an audit trail that they can use to determine the source of a trans |
1,247 | action or attempted transaction and to monitor users’ activities. The way in which organizations configure system or security software determines the nature and extent of information that can be provided by the audit trail. To be effective, organizations should configure their software to collect and maintain audit trails that are sufficient to track security events. A comprehensive security program of the type described is a prerequisite for the protection of personally identifiable information held by age |
1,248 | ncies. In addition, agencies are subject to requirem specifically related to personal privacy protection, which come primarily from two laws, the Privacy Act of 1974 and the E- Government Act of 2002. The Privacy Act places lim disclosure, and use of personal information maintained in systems of records. The act describes a “record” as any item, collect ion, or grouping of information about an individual that is maintained by an agency and contains his or her name or another personal identifier.itations on |
1,249 | agencies’ collection, It also defines “system of records” as a group of records under the control of any agency from which information is retrieved by the name of the individual or by an individual identifier. The Privacy Ac t requires that when agencies establish or make changes to a system of records, they must notify the public by a “system-of-records notice”: that is, a notice in the Federal Register identifying, among other things, the type of data collected, the types of individuals about whom informa |
1,250 | tion is collected, the intended “routine” uses o data, and procedures that individuals can use to review and corr personal information. Among other provisions, the act also requires agencies to define and limit themselves to specific predefined purposes. The provisions of the Privacy Act are consistent with and large based on a set of principles for protecting the privacy and security of personal information, known as the Fair Information Practices, which have been widely adopted as a standard benchmark for |
1,251 | evaluating the adequacy of privacy protections; they include such principles as openness (keeping the public informed about privacy policies and practices) and accountability (those controlling the collection or use of personal information should be accountable for taking steps to ensure the implementation of these principles). The E-Government Act of 2002 strives to enhance protection for personal information in government information systems by requiring that agencies conduct privacy impact assessments ( |
1,252 | PIA PIA is an analysis of how personal information is collected, st shared, and managed in a federal system. More specifically, according to OMB guidance, a PIA is to (1) ensure that handling conforms to applicable legal, regulatory, and policy requirem ents regarding privacy; (2) determine the risks and effects of collecting maintaining, and disseminating information in identifiable form in , an electronic information system; and (3) examine and evaluate protections and alternative processes for handling i |
1,253 | nformation to mitigate potential privacy risks. To the extent that PIAs are made publicly available, they provide explanations to the public about such things as the information that will be collected, why it is bein collected, how it is to be used, and how the system and data will b maintained and protected. Federal laws to date have not required breaches to the public, although breac important role in the context of security breaches in the private sector. For example, requirements of California state law |
1,254 | led ChoicePoint, a large information reseller, to notify its customer a security breach in February 2005. Since the ChoicePoint notification, bills were introduced in at least 44 states and enacted in at least 29 that require some form of notification upon a breach. agencies to report security h notification has played an A numbe in 2005 in the wake of the ChoicePoint security breach as well as incidents at other firms. In March 2005, the House Subcommittee on Commerce, Trade, and Consumer Protection of th |
1,255 | e House Energy r of congressional hearings were held and bills introduced and Commerce Committee held a hearing entitled “Protecting Consumers’ Data: Policy Issues Raised by ChoicePoint,” which focused on potential remedies for security and privacy concern s regarding information resellers. Similar hearings were held by th House Energy and Commerce Committee and by the U.S. Senate Committee on Commerce, Science, and Transportation in spring 2005. In carrying out its mission of providing health care and bene |
1,256 | fits to veterans, VA relies on a vast array of computer systems and telecommunications networks to support its operations and store sensitive information, including personal information on veterans. VA’s networks are highly interconnected, its systems support many users, and the department has increasingly moved to more interactive, Web-based services to better meet the needs of its customers. Effectively securing these computer systems and networks is critical to the department’s ability to safeguard its a |
1,257 | ssets, maintain the confidentiality of sensitive veterans’ health disability benefits information, and ensure the integrity of its financial data. In this complex IT environment, VA has faced long-standing challenges in achieving effective information security across the department. Our reviews identified wide-ranging, often recurring deficiencies in the department’s information security controls (attachment 2 provides further detail on our reports and the area weakness they discuss). Examples of areas of d |
1,258 | eficiency include th following. Access authority was not appropriately controlled. A basic management objective for any organization is to protect the resources that support its critical operations from unauthorized access. Electronic access controls are intended to prevent, limit, and detect unauthorized access to computing resources, prog and information and include controls related to user accounts and passwords, user rights and file permissions, logging and monitori of security-relevant events, and netw |
1,259 | ork management. Inadequate controls diminish the reliability of computerized information and increase the risk of unauthorized disclosure, modification, and destruction of sensitive information and disruption of service. However, VA had not established effective electronic access controls to prevent individuals from gaining unauthorized acces its systems and sensitive data, as the following examples illustra ● User accounts and passwords: In 1998, many user accounts at four VA medical centers and data cente |
1,260 | rs had weaknesses including passwords that could be easily guessed, null passwords, and passwords that were set to never expire. We also found numerous instances where medical and data center staff members were sharing user IDs and passwords. ● User rights and permissions: We reported in 2000 that three VA health care systems were not ensuring that user accounts w broad access to financial and sensitive veteran informa proper authorization for such access, and were not reviewing these accounts to determine |
1,261 | if their level of access remained appropriate. ● Logging and monitoring of security-related events: In 1998, VA did not have any departmentwide guidance for monitoring both successful and unsuccessful attempts to access system files containing key financial information or sensitive veteran data, and none of the medical and data centers we visited were actively monitoring network access activity. In 1999, we found that one data center was monitoring failed access attempts, but was not monitoring successful a |
1,262 | ccesses to sensitive data and resources for unusual or suspicious activity. Network management: In 2000, we reported that one of the health care systems we visited had not configured a network parameter to effectively prevent unauthorized access to a network system; this same health care system had also failed to keep its network system software up to date. Physical security controls were inadequate. Physical security co resources from espionage, sabotage, damage, and theft. These co lim are housed and by p |
1,263 | eriodically reviewing the access granted, in order to ensure that access continues to be appropriate. VA hadntrols are important for protecting computer facilities and ntrols restrict physical access to computer resources, usually by iting access to the buildings and rooms in whic weaknesses in the physical security for its computer facilities example, in our 1998 and 2000 reports, we stated that none of th facilities we visited were adequately controlling access to their computer rooms. In addition, in 199 |
1,264 | 8 we reported that sensitive equipment at two facilities was not adequately protected, increas the risk of disruption to computer operations or network communications. ing Employees were not prevented from performing incompatible duties. Segregation of duties refers to the policies, procedures, a organizational structures that help ensure that one individual can independently control all key aspects of a process or computer- related operation. Dividing duties among two or more indi organizational grouvidual |
1,265 | s or wps diminishes the likelihood that errors and individual or group will serve as a check on the activities of the other. We determined that VA did not assign employee duties and responsibilities in a manner that segregated incompatible functions among individuals or groups of individuals. For example, in 1998 reported that some system programmers also had security administrator privileges, giving them the ability to eliminate anyrongful acts will go undetected, because the activities of one evidence of |
1,266 | their activity in the system. In 2000, we reported tha t two VA health care systems allowed some employees to request,approve, and receive medical items without management approval , violating both basic segregation of duties principles and VA policy; in addition, no mitigating controls were found to alert management of purchases made in this manner. d independently reviewed. We ound that VA did not adequately control changes to its operating Software change control procedures were not consistently implemen |
1,267 | ted. It is important to ensure that only authorized and fu tested systems are placed in operation. To ensure that changes to systems are necessary, work as intended, and do not result in the loss of data or program integrity, such changes should be documented, authorized, tested, an f systems. For example, in 1998 we reported that one VA data center had not established detailed written procedures or formal guidance for modifying operating system software, for approving and testing operating system software |
1,268 | changes, or for implementing these changes. The data center had made more than 100 system softwar changes during fiscal year 1997, but none of the changes included evidence of testing, independent review, or acceptance. We report in 2000 that two VA health care systems had not established procedures for periodically reviewing changes to standard application programs to ensure that only authorized program code was implemented. ed Service continuity planning was not complete. In addition to protecting data an |
1,269 | d programs from misuse, organizations mu ensure that they are adequately prepared to cope with a loss operational capability due to earthquakes, fires, accidents, sabotage or any other disrup c continuity plan. Such a plan is critical for helping to ensure that information system operations and data can be promptly restored in the event of a disaster. We reported that VA had not completed o tested service continuity plans for several systems. For example, in 1998 we reported that one VA data center had 17 i |
1,270 | ndividual disastertion. An essential element in preparing for such atastrophes is an up-to-date, detailed, and fully tested service recovery plans covering various segments of the organization, but itdid not have an overall document that integrated the 17 separate plans and defined the roles and responsibilities for the disaster recovery teams. In 2000, we determined that the service continuity plans for two of the three health care systems we visited did not include critical elements such as detailed recov |
1,271 | ery procedures, provisions for restoring mission-critical systems, and a list of key contacts; in addition, none of the health care systems we visited were fully testing their service continuity plans. These deficiencies existed, in part, because VA had not implemen key components of a comprehensive computer security program . Specifically, VA’s computer security efforts lacked ● clearly delineated security roles and responsib regular, periodic assessments of risk; ● security policies and procedures that ad |
1,272 | dressed all aspects of VA’s interconnected environment; ● an ongoing security monitoring program to identi investigate unauthorized, unusual, or suspicious access activity; and ● a process to measure, test, and report effectiveness of computer system, network, and process controls. As a result, we made a number of recommendations in 2002 were aimed at improving VA’s security management. primary elements of these recommendations were that (1) VA centralize its security management functions and (2) it perform |
1,273 | other actions to establish an information security program, including actions related to risk assessments, security policies procedures, security awareness, and monitoring and evaluating computer controls. GAO, Veterans Affairs: Sustained Management Attention Is Key to Achieving Information Technology Results, GAO-02-703 (Washington, D.C.: June 12, 2002). security policies and procedures. However, the department still needed to develop policy and guidance to ensure (1) authority and independence for securi |
1,274 | ty officers and (2) departmentwide coordination of security functions. Periodic risk assessments: VA is implementing a commercial too identify the level of risk associated with system changes and also to conduct information security risk assessments. It also created a methodology that establishes minimum requirements for such risk assessments. However, it has not yet completed its risk assessment policy and guidance. VA reported that such guidance was forthcoming as part of an overarching information system |
1,275 | security certification and accreditation policy that was to be developed during 2006. Without these elements, VA cannot be assured that it is appropriately performing risk assessments departmentwide. Security policies and procedures: VA’s cyber security officer reported that VA has action ongoing to develop a process for collecting and tracking performance data, ensuring management action when needed, and providing independent validation of reported issues. VA also has ongoing efforts in the area of dete r |
1,276 | eporting, and responding to security incidents. For example, it established network intrusion prevention capability at its four enterprise gateways. It is also developing strategic and tactical to complete a security incident response program to monitor suspicious activity and cyber alerts, events, and incidents. Howe these plans are not complete. Security awareness: VA has taken steps to improve security awareness training. It holds an annual department information security conference, and it has developed |
1,277 | a Web portal for security training, policy, and procedures, as well as a security awareness course that VA employees are required to review annually. Ho VA has not demonstrated that it has a process to ensure complia wever, nce. Monitoring and evaluating computer controls: VA established a process to better monitor and evaluate computer controls by tracking the status of security weaknesses, corrective actions taken, and independent validations of corrective actions through a software data base. However, m |
1,278 | ore remains to be done in this area. For example, although certain components of VA reported vulnerability and penetration testing to evaluate controls on and external access to VA systems, this testing was not part of an ongoing departmentwide program. ince our last report in 2002, VA’s IG and independent auditors have S continued to report serious weaknesses with the department’s information security controls. The auditors’ report on internal controls, prepared at the completion of VA’s 2005 financial sta |
1,279 | tement audit, identified weaknesses related to access cont rol, segregation of duties, change control, and service continuity—a li of weaknesses that are virtually identical to those we identified years earlier. The department’s FY 2005 Annual Performance an Accountability Report states that the IG determined that many information system security vulnerabilities reported in national audits from 2001 through 2004 remain unresolved, despite the department’s actions to implement IG recommendations in pre audit |
1,280 | s. The IG also reported specific security weaknesses and vulnerabilities at 45 of 60 VA health care facilities and 11 of 21 VA t regional offices where security issues were reviewed, placing VA a risk that sensitive data may be exposed to unauthorized access and improper disclosure, among other things. As a result, the IG determined that weaknesses in VA’s information technology controls were a material weakness. In response to the IG’s findings, the department indicates that plans are being implemented to |
1,281 | address the material weakness in information security. According to the department, it has ma limited resources to make significant improvement in its overall security posture in the near term by prioritizing FISMA remediation activities, and work will continue in the next fiscal year. Despite these actions, the department has not fully implemented the key elements of a comprehensive security management program, and its efforts have not been sufficient to effectively protect its information systems and info |
1,282 | rmation, including personally identifiable information, from unauthorized disclosure, misuse, or loss. In addition to establishing a robust information security program, agencies can take other actions to help guard against the possibil that personal information they maintain is inadvertently compromised. These include conducting privacy impact assessments and taking other practical measures. It is important that agencies identify the specific instance they collect and maintain personal information and proa |
1,283 | ctively assess the means they intend to use to protect this information. This can be done most effectively through the development of privacy impact assessments (PIAs), which, as previously mentioned, are required by the E-Government Act of 2002 when agencies use information technology to process personal information. PIAs are important because they serve as a tool for agencies to fully consid the privacy implications of planned systems and data collections before those systems and collections have been ful |
1,284 | ly implemen when it may be relatively easy to make critical adjustments. In prior work we have found that agencies do not always conduct PIAs as they are required. For example, our review of selected data mining efforts at federal agencies determined that PIAs were not always being done in full compliance with OMB guidance. Similarly, as identified in our work on federal agency use of information resellers, few PIAs were being developed for systems or programs that made use of information reseller data, bec |
1,285 | ause officials did not believe they were required. Complete assessments are an important tool for agencies to identify areas of noncompliance with federal privacy laws, evaluate risks arising from electronic collection and maintenance of information about individuals, and evaluate protections or alternative processes needed to mitigate the risks identified. Agencies that do not take all the steps required to the privacy of personal information risk the improper exposure o alteration of such information. We |
1,286 | recommended that the agencies responsible for the data mining efforts we reviewed complete or revise PIAs as needed and make them available to the public. We also recommended that OMB revise its guidance to clarify the applicability of the E-Gov Act’s PIA requirement to the use of personal information from resellers. OMB stated that it would discuss its guidance with agency senior officials for privacy todetermine whether additional guidance concerning reseller dat needed. Besides strategic approaches suc s |
1,287 | ecurity program and conducting range of specific practical measures for protecting the privacy andh as establishing an information PIAs, agencies can consider a r security of personal information. Several that may be of particula value in preventing inadvertent data breaches include the following Limit collection of personal information. One item to be analyzed as part of a PIA is the extent to which an agency needs to collect personal information in order to meet the requirements of a specific application. |
1,288 | Limiting the collection of personal information, amon g other things, serves to limit the opportunity for that information to be compromised. For example, key identifying information—such as Social Security numbers—may not be needed for many agency applications that have databases of other personal information. Limiting the collection of personal information is also one of the information practices, which are fundamental to the Privacy Act to good privacy practice in general. Limit data retention. Closely |
1,289 | related to limiting data collection is limiting retention. Retaining personal data longer than needed by an agency or statutorily required adds to the risk that the data will be compromised. In discussing data retention, California’s Office of Privacy Protection recently reported an example in which a university experienced a security breach that exposed 15-year-old data, including Social Security numbers. The university subsequently reviewed its policies and decided to shorten the retention period for cert |
1,290 | ain types of information. As part of their PIAs, federal agencies can make decisions up front about how lon they plan to retain personal data, aiming to retain the data for as brief a period as necessary. Limit access to personal information and train personnel accordingly. Only individuals with a need to access agency databases of personal information should have such access, and controls should be in place to monitor that access. Further, agenc ies can implement technological controls to prevent personal |
1,291 | data from being readily transferred to unauthorized systems or media, such as laptop computers, discs, or other electronic storage devices. Security training, which is required for all federal employees under FISMA, can include training on the risks of exposing personal dat a to potential identity theft, thus helping to reduce the likelihood of data being exposed inadvertently. Consider using technological controls such as encryption wh data need to be stored on portable devices. In certain instances, agenc |
1,292 | ies may find it necessary to enable employees to have access to personal data on portable devices such as laptop computers. As discussed, this should be minimized. However, when absolutely necessary, the risk that such data could be exposed to unauthorized individuals can be reduced by using technological controls such as encryption, which significantly limits the ability of such individuals to gain access to the data. Although encrypting data adds to the operational burden on authorized individuals, who mu |
1,293 | st enter pass codes or use other authentication means to convert the data into readable text, it can provide reasonable assurance that stolen or lost computer equipment will not result in personal data being compromised, as occurred in the recent incident at VA. A decision about whether to use encryption would logically be made as an en element of the PIA process and an agency’s broader information security program. While these suggestions do not amount to a complete presc ription for protecting personal da |
1,294 | ta, they are key elements of an agency’s strategy for reducing the risks that could lead to identity theft. In the event a data breach does occur, agencies must respond quickly in order to minimize the potential harm associated with identity theft. The chairman of the Federal Trade Commission has testified that the Commission believes that if a security breach creates a significant risk of identity theft or other related harm, affected consumers should be notified. The Federal Trade Commission has also repo |
1,295 | rted that the overall cost of an incide identity theft, as well as the harm to the victims, is significantly smaller if the misuse of the victim’s personal information is discovered quickly. Applicable laws such as the Privacy Act currently do not req agencies to notify individuals of security breaches involving their personal information; however, doing so allows those affected th opportunity to take steps to protect themselves against the d of identity theft. For law is credited with bringing to the publi |
1,296 | c’s notice large data breaches within the private sector, such as those involving ChoicePoint and LexisNexis last year. Arguably, the California lawexample, California’s data breach notification may have mitigated the risk of identity theft to affected individuals by keeping them informed about data breaches and thus enabling them to take steps such as contacting credit bureaus to have fraud alerts placed on their credit files, obtaining copies of their credit reports, scrutinizing their monthly financial a |
1,297 | ccount statem taking other steps to protect themselves. Breach notification is also important in that it can help an organization address key privacy rights of individuals, in accordanc with the fair information practices mentioned earlier. Breach notification is one way that organizations—either in the private sector or the government—can follow the openness principle and meet their responsibility for keeping the public informed of how their personal information is being used and who has access to it. Equa |
1,298 | lly important, notification is consistent with the principle that those controlling the collection or use of personal information should be accountable for taking steps to ensure the implementa of the other principles, such as use limitation and security safeguards. Public disclosure of data breaches is a key step in ensuring that organizations are held accountable for the protection of personal information. Although the principle of notifying affected individuals (or the public) about data breaches has cle |
1,299 | ar benefits, determining the specifics of when and how an agency should issue such notifications presents challenges, particularly in determining the specific criteria for incidents that merit notification. In congressional testim ony, the Federal Trade Commission raised concerns about the thres hold at which consumers should be notified of a breach, cautioning tha strict a standard could have several negative effects. First, notification of a breach when there is little or no risk of harm might create unne |
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