In a preliminary report, the Cyber Secure Institute, an organization headed by former government officials and IT executives, calls NIST's Recommended Security Controls for Federal Information Systems and Organizations, also known as Special Publication 800-53, "an important step forward," but finds that the publication raises "a number of serious questions."
NIST published a final version of those security controls, which were developed with input from civilian, defense, and intelligence agencies, earlier this month. The 236-page publication provides guidelines for federal agencies to meet under the Federal Information Systems Management Act, or FISMA.
Among the shortcomings identified by the Cyber Secure Institute was NIST's classification system for assigning "impact" to government systems. NIST instructs agencies to determine if systems are low, moderate, or high impact and take certain security measures based on those assessments. The Cyber Secure Institute worries that low- and moderate-impact systems won't be adequately protected against "highly-skilled, highly-motivated and well-resourced" attackers.
"High end threats are now the norm, not the exception," The Cyber Secure Institute notes, pointing to the Russian mob, the Chinese military, organized cyber-criminals, and insiders as examples.
The institute also notes that some systems that might be regarded as high impact by the public, such as a law enforcement system of investigative information or a healthcare IT system, are only of moderate impact, according to NIST guidelines.
"Increasingly the Federal government holds critical information about each of us, and its systems have a regular and systemic impact on our day-to-day lives," the report says. "The Federal IT ramifications for every American are only going to increase given the President's IT initiatives, such as e-Health. Yet, the only individual impacts that can push a system into the high impact category are death, life-threatening and serious financial harm."
An even bigger gap, according to the Cyber Secure Institute, is a lack of "measurable or certified performance standards and validation processes." NIST doesn't mandate that systems be tested to see if they measure up to its requirements, and there's no third-party validation process. Even high-end systems only need be sufficiently documented for analysis and testing.
"If the NIST wanted to impose a certification regime, to actually ensure the level of security across the unclassified federal IT realm, it could easily have done so by relying on its own partner initiative," the Cyber Secure Institute report said, noting that NIST is part of the National Information Assurance Partnership, which has the ability to test and certify products.
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