Octave PDF
Octave PDF
Octave PDF
Practitioners Report
Author
Carol Woody, PhD
Contributors
Johnathan Coleman
Michael Fancher
Carol Myers
Lisa Young
May 2006
Technical Note
CMU/SEI-2006-TN-010
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Contents
Abstract................................................................................................................ vii
1 Introduction.................................................................................................... 1
References........................................................................................................... 37
CMU/SEI-2006-TN- 010 i
ii CMU/SEI-2006-TN- 010
List of Figures
CMU/SEI-2006-TN- 010 v
vi CMU/SEI-2006-TN- 010
Abstract
The CERT Operationally Critical Threat, Asset, and Vulnerability EvaluationSM (OCTAVE®)
method, an approach for managing information security risks, was designed to be sufficiently
flexible for organizations to address unique and highly contextual analysis needs through
tailoring capabilities. This document describes how OCTAVE has been used and tailored to
fit a wide range of organizational risk assessment needs. Guidelines for successful tailoring,
built on the reporting practitioners’ successes, are provided to help organizations fit the
OCTAVE approach to their specific domain and organizational needs. The range of
applications demonstrates the flexibility of the OCTAVE approach and its value in addressing
security risk management.
Readers should already be familiar with the general concepts of the OCTAVE approach.
The CERT Operationally Critical Threat, Asset, and Vulnerability Evaluation SM (OCTAVE ® )
method, an approach for managing information security risks, has been successfully tailored
to address a wide range of organizational domains and contexts. After a group of these
experiences were analyzed, patterns of effective tailoring emerged that can help those
evaluating the OCTAVE approach’s applicability to their organizational needs. This technical
note describes those patterns and includes examples from four different domains.
• Section 2 describes the value of a balanced approach to security risk management and the
characteristics of the OCTAVE approach that support this balance.
• Section 3 provides general guidelines for tailoring the OCTAVE approach to fit the needs
of a specific organizational domain and context.
• Section 4 describes the tailoring and use of the OCTAVE approach in four unique
domains by contributors who are experts in their fields: healthcare, manufacturing, state
and local government, and higher education. It also includes a case study for higher
education.
• Section 5 provides information about the contributors who have shared their experiences
for the benefit of others considering the OCTAVE approach. It has been a privilege to
work with them in this effort.
SM
Operationally Critical Threat, Asset, and Vulnerability Evaluation is a service mark of Carnegie
Mellon University.
®
OCTAVE is registered in the United States Patent and Trademark Office by Carnegie Mellon
University.
CMU/SEI-2006-TN- 010 1
2 About OCTAVE
As shown in Figure 1, there are many methodologies that address individual parts of an
organization’s risk management needs. Organizations may look at what others within their
domain have used as viable options, focusing on laws and regulations. Organizations may be
mandated to apply specific standards to achieve regulatory compliance. In addition, an
organization’s size and financial resources help determine appropriate choices. For example,
adoption of a general standard of due care, such as International Organization for
Standardization (ISO) 17799, can be prohibitively costly and does not guarantee that the
security issues of a specific organization have been addressed. Each organization must
understand its risk and plan for appropriate protection.
2 CMU/SEI-2006-TN- 010
An attempt to classify risk assessment methods was published by Sandia National
Laboratories in 2004 [Campbell 2004]. Campbell and Stamp identified three categories: (1)
temporal methodologies that focus on technology systems using actual tests, (2) comparative
methodologies that concentrate on a specific standard, and (3) functional methodologies that
balance the other two to apply tests and standards. OCTAVE is classified as a functional
methodology. The strength of this methodology type is that specific threats, vulnerabilities,
assets, and countermeasures important to the context of the organization are included.
Campbell and Stamp’s classification approach identifies two factors—(1) knowledge of the
methodology and (2) contextual knowledge—that must be balanced for the methodology to
be applied successfully. It also defines who must lead the process [Campbell 2004]: experts
lead when methodology knowledge is critical, and system owners lead when contextual
knowledge is critical. OCTAVE is classified as mid-level and balances the two extremes.
Some organizations apply OCTAVE unassisted, and others enlisted vendors to supplement
their knowledge of security risk management.
The OCTAVE approach uses an asset-based information security risk assessment. Security
risk is carefully considered based on the organizational and technology vulnerabilities that
threaten a group of mission-critical assets. By considering more that just the technology
vulnerabilities that a suite of tools can identify from an organization’s hardware and software
infrastructure, the OCTAVE approach addresses the following questions: 1
By using a balanced approach that blends technology considerations with organizational ones
across a reasonable segment of the organization, an organization should be able to avoid
overprotecting some areas while under protecting others. Figure 2 (by David Biber) provides
a humorous but frequently true depiction of the information security management in an
organization that only considers one portion of the information security risk challenge.
1
Dorofee, A. Asset-Based Information Security Risk Assessments, Cutter Consortium, Enterprise
Risk Management and Governance Executive Report, Vol. 2, No. 6. Available for purchase online at
http://www.cutter.com.
CMU/SEI-2006-TN- 010 3
Figure 2: Results of an Unbalanced Security Risk Management Process
OCTAVE ® -S was developed by SEI under the Technology Insertion, Demonstration, and
Evaluation (TIDE) program (http://www.sei.cmu.edu/tide/) to apply the OCTAVE approach
to small manufacturing organizations. It was released for public use in September 2003.
Guidelines for selecting the OCTAVE method or OCTAVE-S are included in a technical note
published in August 2003 [Alberts 2003]. For the complete timeline of OCTAVE approach
development, see Appendix A.
®
OCTAVE-S is registered in the United States Patent and Trademark Office by Carnegie Mellon
University.
4 CMU/SEI-2006-TN- 010
The OCTAVE method and OCTAVE-S have been widely referenced by the international
information security community. Between June 2003 and June 2005, the OCTAVE method
was downloaded by more than 9,600 sources. During this same time frame, OCTAVE-S was
downloaded by more than 4,700 sources. This group of potential users included private
companies (50%), individuals (15%), academic institutions (15%), and government
organizations (10%). On average, the OCTAVE Web site receives 5,000 visitors a month.
Familiarity with the OCTAVE approach will enhance understanding of this technical note.
Two important sources of OCTAVE information are (1) the OCTAVE Web site
(http://www.cert.org/octave) and (2) Managing Information Security Risks: The OCTAVE
Approach [Alberts 2002].
CMU/SEI-2006-TN- 010 5
3 Applying OCTAVE to an Organization
There are several key areas that must be linked to the organization’s context and domain
(e.g., healthcare or education) to effectively apply an OCTAVE-based methodology. The
following key areas must be understood and the methodology may require tailoring for an
appropriate fit:
• The catalog of security practices used to assess risk must address the regulatory and
accepted security practices for the organizational domain.
• The ways in which risk assessment information is gathered must fit the organizational
context.
• The documents produced as the methodology is used should be written for the
organization’s decision makers using the appropriate level of detail and context-specific
terminology.
• The threats considered within the analysis steps must be consistent with those considered
relevant to the organization.
• Evaluation criteria used to assess a risk’s impact on the organization and to prioritize
risks for mitigation considerations must be based on relevant organizational measures.
Sections 3.1 through 3.5 address the tailoring needs listed above in more detail. In addition,
when applying an OCTAVE methodology—with or without tailoring—the following general
guidelines are critical for embedding the organizational context into the OCTAVE approach.
These guidelines should be considered as each execution of OCTAVE is planned:
• The analysis team should include individuals familiar with the organization and the
OCTAVE approach. External resources may be the most appropriate OCTAVE source of
this expertise if internal resources are not already trained. Tailoring requires participation
by organizational and OCTAVE resources.
• The information sources included in the assessment do not need to be exhaustive, but
they must provide a reasonably complete context. They should represent sufficient
knowledge of the organization, the specific organizational areas selected for analysis, and
the information assets selected for critical analysis.
• Information security management is a subset of organizational risk, and the organization
may benefit from a coordinated range of assessment efforts that address enterprise risk
management.
6 CMU/SEI-2006-TN- 010
3.1 Evaluating the OCTAVE Catalog of Practices
Two types of review are required:
1. Necessary Validation: Is the catalog of practices (COP) used by the OCTAVE approach
relevant to the organization?
2. Sufficiency Validation: Are any aspects of security regulation and practice that are
critical to the organization missing from the catalog?
Begin with a review of OCTAVE COP sources [Alberts 2001b]. Because the OCTAVE COP
was based on a reasonable set of good security practices applicable to the healthcare and
manufacturing domains, experience has generally shown that the catalog is necessary, but it
may not be sufficient. If a domain has well-defined security practices, map them to the
OCTAVE COP to identify strengths and limitations. For a mapping between OCTAVE COP
and National Institute of Standards and Technology Special Publication (NIST SP) 800-30,
see Appendix B.
If a domain does not have well-defined security practices (e.g., education), appropriate
practices can be developed by evaluating security events and problems relevant to the
domain. Sources include domain-specific books and articles, general news publications, and
technology publications such as the “SANS NewsBites” (http://www.sans.org/newsletters)
and AIG National Union’s “Top Ten Tech Issues.”
For each critical event, the relevant security risk, consequence, and security practice can be
assembled. Using this technique for K-12 schools and school districts yielded the following
security practices that were not included in the OCTAVE COP [Woody 2004]:
• content blocking to filter pornography and limit access to inappropriate activities (e.g.,
gambling) and monitoring to minimize the impacts of censorship
• structured access to ensure privacy, accommodate device sharing, and control access
rights
• regulatory compliance for the Children’s Online Privacy Protection Act (COPPA),
application of copyright and licensing laws to digital media, and the USA PATRIOT Act
• acceptable educational uses to assign appropriate levels of responsibility to participants
based on age level, allow appropriate organizational use of available digital content, and
promote ethical behavior
CMU/SEI-2006-TN- 010 7
addressed from an enterprise perspective. There is no set number of workshops that can be
performed for an assessment: however, each workshop increases the volume of information
that an analysis team must evaluate.
OCTAVE-S requires that the analysis team contains sufficient organizational knowledge to
provide the enterprise perspective without additional information gathering steps. The
methodology is streamlined for the less formal style of small organizations, and it assumes
that the organization has a limited number of security experts participating in the process.
The analysis team uses OCTAVE-S templates—comprised of standard text, selection boxes,
and notes—to guide and document security discussions. Because the templates are so
detailed, OCTAVE-S tailoring would be tedious and has not been reported to SEI.
Many different types of information gathering have been successfully applied. Web survey
forms have been used to gather input from broadly disbursed organizational units and
participants with unusual schedules who cannot easily attend workshops. Individual
interviews have been conducted when workshop participation is not supported. While this
allows in-depth discussions and ensures input from all participants, it extends the
organizational information gathering and analysis activities. Therefore, the benefits should be
clearly articulated to justify the additional time.
8 CMU/SEI-2006-TN- 010
Figure 3: Information Security Risk Evaluation Within an Information Security Risk
Management Process
There are unique groups of actors who may be trusted outsiders (e.g., consultants, students,
and vendors providing on-site support). If these groups are sufficiently large, the analysis
team may choose to consider their actions separately and modify the generic threat trees.
CMU/SEI-2006-TN- 010 9
Not all organizations are prepared to address risks for each general criterion. For example,
life and health of customers is very relevant to a medical organization, but it is less important
to a financial institution, which may decide to drop the criterion. For Kindergarten through
12th grade (K-12) schools and school districts, none of the general criteria proved relevant.
For this domain, the primary concern is lost of teaching moment opportunities. Criteria were
adjusted to reflect this critical evaluation type, and threats were evaluated based on the
number of possible classroom hours jeopardized [Woody 2004].
10 CMU/SEI-2006-TN- 010
4 OCTAVE in Practice
This section describes ways in which the OCTAVE approach was successfully tailored to
meet the contextual issues of organizations in four different domains (healthcare,
manufacturing, state government, and higher education). Where available, the specific
methodology that was used, the OCTAVE method or OCTAVE-S, is specified. This material
was provided by individuals who are actively applying the OCTAVE approach to address
their security risk management challenges. Each contributor responded to the following
questions to help you understand how using the OCTAVE approach could enhance your
organization’s security risk management:
• What made OCTAVE the right choice for the basis of risk management?
• What makes this use of OCTAVE unique?
• What makes this a success story?
• What lessons learned were identified to allow for improvement the next time?
In Section 4.1, Johnathan Coleman addresses HIPAA-mandated risk assessments using the
OCTAVE method. He shares the steps required to apply security risk management to address
healthcare regulatory requirements as implemented within the DoD.
In Section 4.2, Michael Fancher describes enhancements to the OCTAVE approach by the
National Center for Manufacturing Sciences. He shares techniques, applied to a range of
organizations, that were used to integrate security risk management into manufacturing
practices.
In Section 4.3, Lisa Young reports on how Florida tackles enterprise risk management (ERM)
with the OCTAVE method and NIST SP 800-30 to effectively incorporate security risk
management. She includes a correlation of the OCTAVE method to NIST SP 800-30 (see
Appendix A).
In Section 4.4, Carol Meyers describes how Paradise Valley Community College, a part of
the Maricopa Community College District, tailored the OCTAVE approach for security risk
management. Carol Myers shares her experience linking information security risk into the
college’s overall risk management program.
In Section 4.5, Carol Meyers provides a case example of how the OCTAVE method was used
in an information technology security risk assessment for the Telescopes in Education Project
at Paradise Valley Community College.
CMU/SEI-2006-TN- 010 11
4.1 Addressing HIPAA-Mandated Risk Assessments with
OCTAVE
Background
The Administrative Simplification provisions of the Health Insurance Portability and
Accountability Act of 1996 (HIPAA, Title II) require the Department of Health and Human
Services (HHS) to establish national standards for the security of electronic healthcare
information. The final rule [HHS 2003] adopting HIPAA standards for security was published
in the Federal Register on February 20, 2003 with two compliance deadlines: (1) April 21,
2005 for all covered entities except small health plans and (2) April 21, 2006 for small health
plans.
This final rule specifies a series of administrative, technical, and physical security safeguards
for covered entities to use to ensure the confidentiality, integrity, and availability of
personally identifiable electronic health information (subsequently referenced as electronic
protected health information). The standards are delineated into required or addressable
implementation specifications.
The standard §164.308(a)(1) is the security management process. It states that a covered
entity must implement policies and procedures to prevent, detect, contain, and correct
security violations. Risk analysis and risk management are required implementation
specifications for this standard.
Risk Analysis: Covered entities must conduct an accurate and thorough assessment of the
potential risks and vulnerabilities to the confidentiality, integrity, and availability of
electronic protected health information held by the covered entity.
Risk Management: Covered entities must implement security measures sufficient to reduce
risks and vulnerabilities to a reasonable and appropriate level to comply with the required
HIPAA safeguards.
As part of an early initiative to get a head start in meeting these requirements, the Security
Working Integrated Project Team (WIPT), Office of the Assistant Secretary of
Defense/Health Affairs (OASD/HA) endorsed OCTAVE as the preferred information security
risk assessment approach. The Security WIPT is a subgroup of the HIPAA Overarching
Integrated Project Team that has overall responsibility for coordinating the DoD's effort to
comply with HIPAA. The Security WIPT is responsible for preparing for compliance with the
HIPAA Security Rules. The Defense Health Information Assurance Program (DHIAP)
[Collman 2001], a congressionally directed research project administered by the TATRC in
Ft. Detrick, Maryland, sponsored the development, testing, and deployment of the OCTAVE
method for use in the DoD’s medical treatment facilities (MTFs). Because of this sponsorship
and OASD/HA endorsement, the DoD used the OCTAVE method to standardize risk
assessment at the MTFs while decentralizing the decision-making process during the
assessment [Coleman 2003]. The self-directed nature of the OCTAVE approach required
12 CMU/SEI-2006-TN- 010
interdisciplinary and inter-hierarchical analysis teams (dubbed Medical Information Security
Readiness Teams, or MISRTs) to conduct the analysis for themselves, which resulted in
ownership of the process, meaningful results, and relevant and actionable mitigation plans
and organizational protection strategies.
As a mature, recognized, and robust methodology, the OCTAVE method has been used to
assess information security risk in healthcare organizations that differ in scale, complexity,
and geographic location. Comparing the different implementations of OCTAVE tailoring
techniques [Alberts 2002] and their results have produced some interesting similarities
[Coleman 2004].
First and foremost, the DoD’s OCTAVE evaluations were conducted with this objective:
execute a risk assessment to meet the HIPAA Security Rule requirements. When results were
compared, technical and organizational observations common to several organizations were
identified, which suggests that these issues may be prevalent throughout the industry.
• Individuals at remote sites were included, which increased participation and information
security awareness.
• Individuals responded at their convenience, which resulted in more responses and a
statistically valid level of participation.
While Web-based surveys have many advantages, the contextual emphasis obtained through
facilitated discussions was lost. To counter that, short discussions about current
organizational practices and vulnerabilities were included in the senior and operational
managers’ workshops as appropriate.
CMU/SEI-2006-TN- 010 13
Web-based surveys also produced this unexpected benefit: groups that were not uniquely
identified in standard OCTAVE method workshops could be discovered. In some MTFs, for
example, IT-savvy biomedical staff have sole responsibility for managing biomedical systems
independent of IT staff. By comparing survey responses between these two groups with
similar IT responsibilities, different perspectives of organizational risk can be identified.
For assessments conducted by in-house personnel, the scope was generally focused on
systems and infrastructure under direct control of the IT department, which excluded
biomedical devices. In cases where the risk assessment was led by external technical
consultants, biomedical and other clinical systems were often included as part of the
assessment.
Smaller organizations tended to augment their analysis team with technical security experts
to assist with this part of the risk assessment. Medium-sized organizations generally
conducted this part of the risk assessment in-house with their own security staff. Larger
organizations seeking to reach beyond the confines of a traditional IT security assessment
used outside experts to conduct the Phase 2 portions of the OCTAVE method. Doing so
provides independent validation that IT operational security complies with best practices for
security at a technical level. It also enables organizations to investigate technical, physical,
and administrative procedures for data handling in systems managed by departments other
than IT.
14 CMU/SEI-2006-TN- 010
security policies and practices. Other security challenges identified in the healthcare
organizations included
• difficulty with patch management for server farms and internally-managed systems (not
vendor-managed systems), which presented numerous problems for the security and IT
staff
• difficulty controlling the deployment of service accounts and implementing password
changes on accounts that are widely distributed as integral components of health
information systems
• difficulty addressing the security of biomedical devices because of concerns about
potential vendor warranty issues and challenges in dealing with Food and Drug
Administration (FDA) approved systems
Conclusion
Despite extensive differences in size and complexity among healthcare organizations, a range
of common risks and challenges were identified that indicate a consistent level of security
risk throughout the industry. The convergence of biomedical devices and IT systems and their
growing dependency on the underlying network topology is a prime example. Using a
structured industry-recognized methodology that incorporates good standard security
practices allows healthcare organizations to identify a sufficient level of security risks to meet
HIPAA regulations with effective due diligence. Using a methodology that is sufficiently
flexible to include individualized organizational needs allows healthcare organizations to
justify their decisions by considering their own unique circumstances and differing abilities
to mitigate these risks. OCTAVE is particularly well suited to healthcare organizations. The
COP [Alberts 2001b] incorporated into OCTAVE was developed to address the needs of a
healthcare organization, and the flexibility of the methodology allows an unlimited number of
deployment variations to ensure that the assessment is successful and meaningful.
Organizations’ resource limits and the time required to implement effective protection
strategies and mitigation plans significantly influenced decisions regarding which risks were
ultimately selected for mitigation, deferral, or acceptance. The OCTAVE approach for
evaluating risks in terms of organizational impact was critically important and the most
influential factor considered when prioritizing risks for mitigation. This observation supports
the concept of a decentralized decision-making approach to information security in the
healthcare industry, which allows organizations to prioritize risks for mitigation according to
their own criteria.
CMU/SEI-2006-TN- 010 15
4.2 Enhancements to OCTAVE by the National Center for
Manufacturing Sciences
The National Center for Manufacturing Sciences (NCMS), an organization representing a
consortium of manufacturers, has developed extensions to the baseline OCTAVE approach to
broaden its applicability to the range of enterprise and value chain vulnerability types
important to manufacturing domains. By adding an explicit process modeling step and
expanding the definition of a critical asset, vulnerability assessments of high value to the
enterprise can be effectively carried out, including
Either of the two basic methodologies using the OCTAVE approach originally developed by
SEI (the OCTAVE method and OCTAVE-S) can be employed to execute this expanded,
process-centric adaptation. The principals and processes of the OCTAVE approach are
preserved in the NCMS-extended method, and so are the basic formats (with minor
adaptations). NCMS has successfully applied these extensions to assess critical information
and physical and process assets for the DoD, manufacturers, and organizations in the utility
industry.
Critical processes typically are core, value-adding processes. If compromised, they would
most directly or immediately result in a negative impact on the most important business
metrics/objectives or reduce the ability of the enterprise to fulfill its mission. Alternatively,
critical processes can support other business processes with high potential of negative
business or mission impact should they fail to perform to expected criteria. For example, a
subprocess that fails or degrades due to supply chain contamination or data corruption may
16 CMU/SEI-2006-TN- 010
cause the loss of an entire production run. By missing a shipment date, an organization may
not only lose the order—they may lose an important customer.
• They are essential to achieving the minimum output quality and performance criteria in
the highest-level process within the scope of the assessment.
• When they are compromised, there is an identifiable potential for major negative impact
on the mission, goals, or values of the overall enterprise.
• They are shared among multiple critical processes.
The NCMS process for identifying critical assets through process maps is as follows:
1. Identify and diagram the critical processes to a reasonable level of detail, including
descriptions of the inputs and outputs.
2. Precisely identify the process scope for the assessment.
3. Identify and document in-scope process assets.
4. Select a limited set of critical information and physical assets for the critical processes.
The asset view of a process consists of up to seven major components with which assets may
be associated and identified:
1. process activities
2. physical and information outputs
3. physical and information inputs
4. output quality and performance criteria
5. input quality and performance criteria
6. tools
7. controls
A generic high-level process model with these seven components is shown in Figure 4. This
model is used to document specific processes.
CMU/SEI-2006-TN- 010 17
7
Physical Information
Controls
Assets Assets
Physical Physical
Assets Input Quality Output Assets
and Quality and
Performance Process Performance
3 Inputs Criteria Activities Criteria Outputs 2
Information 5 1 4 Information
Assets Assets
Physical Information
Assets Tools
Assets
The process components Controls and Tools can be comprised of systems, including—but
certainly not limited to—information systems that have both physical and information
dimensions. Process assets can be inventoried using these categories, and the most critical
assets are candidates for vulnerability and risk assessment. As needed, high-level processes
can be hierarchically decomposed into linked subprocesses to expose critical subprocesses,
but NCMS experience has shown that consolidating lists of assets from multiple subprocesses
at a relatively higher process level is generally sufficient to assure that critical assets are
identified.
18 CMU/SEI-2006-TN- 010
Physical Assets
– De-
1. Control valves
2. Flow controls* Information Assets
3. Pressure gauges
4. PLCs 1. Flow
5. Conductivity 2. Turbidity
monitors 3. pH
6. pH and chemical 4. Conductivity
Physical Assets % meters 5. Silica
1. Filtered water
2. Sulfuric acid Controls Physical Assets
3. Sodium hydroxide
Deionized water
DEIONIZATION
Input Quality Output
and Quality and
Inputs Performance Process Activities Performance
Outputs
Criteria Criteria
Identifying critical processes, analyzing the asset view of processes, and selecting critical
process assets in Phase 1 incorporates the process model information collected in Phase 0.
These activities lead in the usual way to the OCTAVE threat tree and recommendations steps,
with appropriate adaptations to analysis and presentation formats.
Conclusion
Through its flexibility in incorporating extensions, the OCTAVE approach has provided
NCMS with a robust and repeatable framework to address risk management for DoD and
industry customers. In addition, prototypes of a failure analysis method and an NCMS-
developed risk management decision process linked within the OCTAVE approach have been
successful. The OCTAVE approach is sufficiently robust to support the active management of
risks related to asset vulnerabilities of essentially any kind, including physical security, anti-
terrorism, and manufacturing process integrity.
CMU/SEI-2006-TN- 010 19
4.3 Florida Tackles Enterprise Risk Management with OCTAVE
and NIST SP 800-30
Background
Government officials have always had a critical role in protecting their citizens from risks.
The risk climate has changed in recent years and handling risk has become more central to
the work of government than ever before.
Florida has dealt with information system risks posed by hurricanes, tornadoes, and floods
for many years. Information technology plays a major role in state and local government,
both fiscally and operationally. The service delivery tools supported by IT have become
critical to the mission of all state and local government agencies.
In an era of heightened alerts, state and local governments face extraordinary challenges.
They must find and close gaps in the public security network and plan effective responses to
critical threats. They need to achieve all this while working under tighter than ever budgets
and rapidly changing technologies.
Florida has a long history of technology initiatives and was the first to implement a state
Computer Security Incident Response Team (CSIRT) program. The CSIRT program,
comprised of teams of employees from each state agency, received critical training from the
SEI and CERT/CC at Carnegie Mellon University on responding to computer security
incidents. The CSIRT teams were created at the direction of Governor Bush as part of the
Florida Infrastructure Protection Center in March 2003.
Further initiatives passed in the 2004 legislative session prepared Florida to weather incidents
caused by computer viruses and cyberterrorism that can have the same, if not greater, impact
than a natural disaster. The legislative mandate, Florida Statute 282.318, is known as the
Security of Data and Information Technology Resources Act. The mandate requires each
agency to conduct a risk analysis to identify security threats to data and information
technology resources.
Risk refers to the potential of direct or indirect loss due to a failure of people, processes,
systems, or external events. This definition acknowledges the uncertainty that underlies much
of the work of government. A risk assessment is the first step in creating a risk management
program. Identifying operational risks that could potentially prevent an agency from
20 CMU/SEI-2006-TN- 010
conducting its mission is the first step to information-protection improvements based on risks
to the confidentiality, integrity, and availability of critical information technology assets.
Risk management refers to the ongoing processes involved in identifying, assessing, and
judging risks; taking actions to mitigate or anticipate them; and monitoring and reviewing
progress. Traditional approaches to information technology risk management are based on
compartmentalizing risks and mitigating those risks independently of each other. A paradigm
shift is taking place in the business and government communities as many organizations
move towards a more holistic model of assessing how risks impact the entire organization.
ERM assists in that transition to a higher-level view of information governance and
protection. This shift towards an ERM framework can help organizations meet their overall
mission, improve service delivery, and save money by using resources more efficiently.
The language of risk management sometimes implies a simpler process than is usually
possible in reality. This is particularly the case in state and local government. Government
entities deal with more complex operating environments, variables, and conflicting
viewpoints than other business fields.
Florida selected a third-party vendor to help with the assessments and transfer knowledge to
the individual entities. The vendor recommended using portions of the OCTAVE
methodology based on the way in which the OCTAVE method aligned with the NIST SP 800-
30 standard. The OCTAVE method, combined with the NIST SP 800-30 standard, could be
customized to meet the range of needs for the various entities.
CMU/SEI-2006-TN- 010 21
As shown in Appendix B, the nine steps of NIST SP 800-30 map directly to segments of the
OCTAVE method.
The process began with a kick-off presentation for senior managers, operational managers,
and business process owners. It introduced the OCTAVE method and how it aligns with NIST
SP 800-30 and explained the risk assessment process that would take place over the next few
weeks.
To reduce time delays for Process 6, each participating organization identified critical assets
and the associated systems before the assessment began. That process’s technology
vulnerability assessment could then be performed in a timely manner. The OCTAVE method
was also expanded by the vendor to assess the physical security risks.
Information security policies were reviewed against NIST standards so that gaps could be
identified.
OCTAVE provides surveys based on the OCTAVE COP. They were used to assess the
organization’s overall awareness and view of information security.
Risks to intangible assets (e.g., the collective institutional knowledge base) were considered
in the analysis. With 64 million baby boomers (over 40 percent of the United States labor
22 CMU/SEI-2006-TN- 010
force) eligible to retire by the end of this decade [Morton 2005], state and local governments
face significant risk over the next five years.
Security issues were analyzed in relation to the business issues instead of vice versa (the
latter being the more traditional OCTAVE method).
Protection Strategy
Creating a protection strategy to mitigate any identified risks is the second step, after
conducting the risk assessment, in an ERM program. Protecting all assets equally is not
possible or fiscally sound. After possible threats are detailed and potential impact is assessed,
one can decide how to appropriately deal with them. NIST guidelines consider many factors
when providing guidelines for implementing controls to mitigate risks.
NIST SP 800-30 assesses the likelihood of a technology vulnerability being exploited, which
differs from the OCTAVE approach that considers the likelihood that an asset-threatening
event will occur. NIST SP 800-30 guidelines recommend using the probability (high,
medium, or low) multiplied by the impact (high, medium, or low) to determine the risk. The
OCTAVE method focuses on the risks that would have the greatest negative impact on the
mission of the organization. The goal of the risk assessments is to create a strategy to protect
the mission of the agency, not just the IT assets.
In NIST SP 800-30, threat sources are listed individually. The NIST SP 800-30 format was
used to identify threat sources and then group them based on possible motivations or threat
action types. Traditional OCTAVE threat trees were not used to graphically assemble related
risks for analysis. By mitigating the most common technology vulnerabilities to protect the
critical assets, other assets are protected by association.
CMU/SEI-2006-TN- 010 23
The protection strategy developed as a result of the risk assessments could also be used to
assess the criticality of system restoration activities after hurricanes or other natural disasters.
Lessons Learned
The biggest lesson learned is that information security and protection of data depends not
only on technology but also on each person’s awareness of their responsibility to protect
critical information assets. Each user has a role in protecting data. Imagine each PC, personal
digital assistant (PDA), voice over Internet protocol (VoIP) phone, or other computing device
as a front door—there is always the potential for some users to leave the key under the mat.
It is easy to lose focus on the strategic aspects of information security, particularly during
Phase 2 when the vulnerabilities were more tactical and the remediation requirements more
immediate. Previous security vulnerability analyses focused on technology only. The
vulnerability assessments provided a list of technical items to remediate but no overall
protection strategy.
The value of the self-assessment compliance questionnaire, which was added to the process
to broaden the level of compliance, was unclear. Questionnaire results, without other
confirming quantitative measurements, might not accurately reflect actual day-to-day
operational practices.
Conclusion
Implementation of an ERM framework, in conjunction with continuous risk management
activities using the NIST standards and the OCTAVE method, supports a shift to a risk-smart
culture in state and local government. Such a culture supports responsible risk management
and builds it into existing governance and organizational structures as well as planning and
operational processes. An essential element of a risk-smart culture is to ensure that the
workforce has the capacity and tools to innovate while recognizing and respecting the need to
be prudent in protecting public interest and maintaining public trust.
Achieving this cultural change will require sustained commitment from state and local
government for many years as risk management practices in information security evolve.
24 CMU/SEI-2006-TN- 010
4.4 Paradise Valley Community College Tailored OCTAVE for
Security Risk Management
Background
Paradise Valley Community College (PVCC) is part of the Maricopa Community College
District (MCCD) that consists of 10 colleges, two skill centers, and many college satellite
centers, including the Arizona state prison. Over 8,000 students are enrolled at PVCC and
supported by approximately 200 employees. This translates to roughly 1,600 network hosts.
MCCD has a decentralized administration: each college has a president and a full
complement of deans. The district office administration handles core, centralized
administrative operations like human resources (HR) and financials. The colleges’ missions
are diverse: some focus on specific academic disciplines, others on occupational education,
and one on distance learning.
Five years ago, MCCD adopted an ERM model that integrates different risk frameworks—
based on insurable risks and other types—across the district. The Maricopa Integrated Risk
Assessment (MIRA) project embraces ERM because employees can collaboratively identify,
assess, and manage future risks and opportunities. In March 2000, the MCCD governing
board—with support from the chancellor and the chancellor’s Executive Council (CEC)—
officially approved MIRA. Later that year, MCCD’s risk manager was charged with
implementing a multi-year plan.
MCCD’s approach to risk management is captured in MIRA’s mission statement, which was
adopted in 2004: “The Maricopa County Community College District endeavors to be an
innovative, flexible higher education institution that encourages risk assessment and
management as an integral process for carrying out our mission to promote and enhance
student learning and success. It is the responsibility of every employee to identify, assess, and
manage risks and opportunities individually, throughout our organization, and to
collaboratively strive for continuous quality improvement and the efficient and effective use
of our resources.” MIRA defined MCCD’S posture toward risk as guidance to specifically-
focused risk assessments.
CMU/SEI-2006-TN- 010 25
OCTAVE was narrowed to focus primarily on operational risks and security practices. The
MIRA project already garnered top-level buy-in for risk assessment and management.
Technology assets would be examined only in relation to good security practices that are part
of the OCTAVE COP. Protection decisions would be based on confidentiality, integrity, and
availability but directed towards technical infrastructure and staff. Policy and procedural
issues identified within or outside of IT would be escalated to the appropriate manager for
analysis and potential mitigation based on general business criteria.
OCTAVE for PVCC was distilled into four phases: (1) system infrastructure analysis and
documentation, (2) risk and opportunity identification, (3) asset cost analysis, and (4)
mitigation strategies and costs. The first two are completed by IT staff, and the latter two are
completed by management. The phases are forms driven and consist of check boxes and short
answers. The forms are self-explanatory and easy to understand and complete. PVCC relies
heavily on them to address the MIRA requirement for a PVCC IT security risk assessment.
Conclusion
PVCC’s tailoring of OCTAVE was validated on a course management system that a vendor
has just assessed. The OCTAVE and vendor results differed in only one instance: the vendor
indicated that information security technical measures were “overbuilt.” Participants
preferred PVCC’s relatively quick and easy information gathering process (via forms and
email) over hours of interviews with staff across the organizational unit.
PVCC endeavored to keep the inherent flexibility of the OCTAVE approach present in its
model. The end result was to provide a simple vehicle for colleges that would fit easily into
their diverse computing environments. This flexibility was validated when another MCCD
college implemented PVCC’s risk assessment and found it useful.
Feedback suggested that much of the terminology was foreign and sometimes confusing for
IT staff. While this is a symptom of first exposure to risk assessment language, it raised the
issue of training. For MIRA to succeed, training sessions that cover terminology and basic
concepts for risk assessment and the OCTAVE approach should be developed for IT staff and
managers.
26 CMU/SEI-2006-TN- 010
4.5 Case Study: An Information Technology Security Risk
Assessment for the Telescopes in Education Project at
Paradise Valley Community College
Background
Science professors have been working on a comprehensive astronomy program through
research and various outreach activities. A major initiative within the program is participating
in the Telescopes in Education (TIE) project. TIE provides students around the world with the
opportunity to remotely control a telescope and charge-coupled device (CCD) camera in a
real-time, hands-on, interactive environment. TIE enables students to increase their
knowledge of astronomy, astrophysics, and mathematics; improve their computer literacy;
and strengthen their critical thinking skills. TIE is sponsored by the National Aeronautics and
Space Administration (NASA) and developed through the efforts of numerous volunteers,
businesses, and supporting organizations, including the Jet Propulsion Laboratory (JPL) of
the California Institute of Technology (Caltech).
The Sky software was purchased last year as the first step required to participate in TIE. To
date, a three-server private network connected to a telescope is in place but not in production.
The system, which is tentatively called the Paradise Valley Astronomical Connection System
(PVACS), was set up using standard business processes but without formal approval from the
appropriate PVCC authorities. An astronomy student working under the auspices of a science
lab technician designed and deployed the system. A preliminary IT risk assessment of PVACS
has been conducted and this evaluation focuses on those results.
CMU/SEI-2006-TN- 010 27
Component Server 1 Server 2 Server 3
For critical day-to-day functions, PVACS ranks at the bottom of the scale (low) for the
college and the astronomy department. Consider that “The telescope control system and
content server were made from parts donated which previously were running distributed
computing 24 hours/7 days a week and are considered extremely stable.” The system has not
yet suffered any repairs or crashes, but they will be documented as they occur. There is no
disaster recovery plan because the system was not in production at the time of this evaluation.
28 CMU/SEI-2006-TN- 010
Business process risks and security risks identified during the PVCC risk assessment for
PVACS are included in Table 2 and Table 3. To comply with the PVCC-tailored OCTAVE
forms, mitigating controls and/or processes are provided for each risk.
The following technology risks are not ranked but require remediation before the system will
be approved for full production:
1. There is no formal patch methodology for the Windows XP servers. This will be
completed pre-production but will not be initially required for development efforts.
2. There is no system access or account creation procedure in place. Root access will be
given to the network administrator for auditing purposes. Strong password methodology
using least privilege must be in place. The network administrator will be responsible for
assigning additional system administrator accounts based solely on business need.
3. Disaster recover plan must be documented and in place.
CMU/SEI-2006-TN- 010 29
Asset and Mitigation Strategy Cost Analysis
If the system’s physical assets were sold, they would net approximately $1,000. Two of the
servers were old, decommissioned desktop machines, and one had been refurbished with
newer components. The astronomy student owns the network switch and the application
software server but is donating the equipment to the college. At this time, asset loss is of little
concern to the business operations of the college. PVACS is not instructionally dependent so
there is no academic risk to mitigate.
Conclusion
This academic year, PVACS should be used strictly as a pilot. The pilot user group should be
Physics and Astronomy Club members and other carefully selected physics and astronomy
students. System use should not be tied to instruction until all risks are mitigated as described
in this document.
30 CMU/SEI-2006-TN- 010
5 About the Contributors
Michael Fancher leads initiatives by the NCMS in security, assessment, and extended ERM
for commercial industry, the DoD, and the public sector. Mike has led the development and
application of advanced integrated assessment and risk management frameworks and tools,
including adaptations of the OCTAVE method. These frameworks and tools enable
enterprise-level leaders and facilities, process, and business unit managers to identify
vulnerabilities of many kinds and to consistently manage the range of risks that affect
business performance or mission.
Carol Myers, CISSP, has worked in IT security for seven years as a designer and
information systems security director. She is currently Director of College Technology for
Paradise Valley Community College. Her technical background includes software design and
development, enterprise systems architecture design and deployment, UNIX administration,
database development, and quality assurance. She has presented nationally on open source
security tool deployment (EDUCAUSE 2003) and IT security risk assessment methodology
and practice (EDUCAUSE/Internet2 Security Professionals 2005 Conference). Carol was
program chair for the EDUCAUSE/Internet2 Security Professionals 2005 Conference, vice-
chair for the 2004 EDUCAUSE/Internet2 Security Professionals Workshop, 2004-2005
member of the EDUCAUSE/Internet2 Security Task Force. She currently serves on the
EDUCAUSE/Internet2 IT Security Risk Assessment Working Group.
Lisa Young, CISA, a managing consultant with DynTek Services, Inc., has over 20 years of
experience in the information technology and telecommunications industry and has addressed
IT governance, information audit and security, and risk management. Lisa is a Visiting
Scientist at the SEI teaching the OCTAVE method. In her most recent engagement with
DynTek, Lisa was the project manager for 15 of the 24 risk assessments conducted for
Florida using the OCTAVE method and NIST SP 800-30 standard. She has extensive
experience with regulatory compliance and security operational procedures.
CMU/SEI-2006-TN- 010 31
32 CMU/SEI-2006-TN- 010
Appendix A Timeline for OCTAVE in Practice
Date Action
May 2003 OCTAVE method artifacts available from the CERT Web site
CMU/SEI-2006-TN- 010 33
34 CMU/SEI-2006-TN- 010
Appendix B NIST SP 800-30/OCTAVE Correlation
NIST SP 800-30 is a standard that provides guidance on the range of risk management
activities for information assets across a system life cycle. Rather than being directive, it
provides general guidance on actions that should be accomplished under the umbrella of risk
management.
Table 4 shows the strong correlation between NIST SP 800-30 steps and the OCTAVE
method processes.
CMU/SEI-2006-TN- 010 35
36 CMU/SEI-2006-TN- 010
References
[Alberts 1999] Alberts, C.; Behrens, S.; Pethia, R.; & Wilson, W. Operationally
Critical Threat, Asset, and Vulnerability EvaluationSM (OCTAVESM)
Framework, Version 1 (CMU/SEI-99-TR-017, ADA367718).
Pittsburgh, PA: Software Engineering Institute, Carnegie Mellon
University, 1999. http://www.sei.cmu.edu/publications/documents
/99.reports/99tr017/99tr017abstract.html
[Alberts 2001b] Alberts, C.; Dorofee, A.; & Allen, J. OCTAVESM Catalog of
Practices, Version 2.0 (CMU/SEI-2001-TR-020, ADA396654).
Pittsburgh, PA: Software Engineering Institute, Carnegie Mellon
University, 2001. http://www.cert.org/archive/pdf/01tr020.pdf
[Alberts 2003] Alberts, C.; Dorofee, A.; Stevens, J.; & Woody, C. Introduction to
the OCTAVE® Approach. http://www.cert.org/octave
/approach_intro.pdf (2003).
CMU/SEI-2006-TN- 010 37
[Coleman 2003] Coleman, J. “Execution of a Self-Directed Risk Assessment
Methodology to Address HIPAA Data Security Requirements,”
224-231. Proceedings of the SPIE – The International Society for
Optical Engineering. Medical Imaging 2003. PACS and Integrated
Medical Information Systems: Design and Evaluation. San Diego,
CA, February 18-20, 2003. Bellingham, WA: Society of Photo-
Optical Engineering (SPIE), 2003.
[Collman 2001] Collman, J. “HIPAA and the Military Health System: Organizing
Technological and Organizational Reform in Large Enterprises,”
126-131. Proceedings of SPIE 2001: Medical Imaging, PACS and
Integrated Medical Information Systems, Design and Evaluation.
San Diego, CA, February 20-22, 2001. Bellingham, WA: SPIE
Press, 2001 (ISBN 0-819-44009-4, TIE ID 11633).
[Collman 2004] Collman, J.; Coleman, J.; Sostrom, K.; & Wright, W. “Organizing
Safety: The Conditions for Successful Information Assurance
Programs.” Journal of Telemedicine and eHealth 10, 3. (September
2004): 311-320.
[HHS 2003] Department of Health and Human Services. “45 CFR Parts 160,
162, and 164. Health Insurance Reform: Security Standards; Final
Rule.” Federal Register 68, 34 (February 2003): 8334 – 8331.
http://www.cms.hhs.gov/SecurityStandard/Downloads
/securityfinalrule.pdf
[Morton 2005] Morton, L.; Foster, L.; & Sedlar, J. Managing the Mature
Workforce. New York, NY: The Conference Board, 2005.
http://www.conference-board.org
38 CMU/SEI-2006-TN- 010
[Woody 2004] Woody, Carol. “Applying Security Risk Management to Internet
Connectivity in K-12 Schools.” PhD thesis, Graduate School of
Computer and Information Sciences, Nova Southeastern University,
2004.
CMU/SEI-2006-TN- 010 39
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