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  • Donald E. Hester

Interagency Connections: Strengthening Cybersecurity in an Interconnected World

Mitigating Risks in Interconnected Government Systems

Imagine a scenario where a government agency, City A, with which your organization has a critical interconnection, falls victim to a devastating cyber breach. In this unfortunate turn of events, the attackers successfully exploited vulnerabilities within City A's system, gaining unauthorized access to sensitive data and compromising their infrastructure. Unbeknownst to your organization, the breach quickly spreads, thanks to the interagency connection shared between your systems. Exploiting this connection as a pathway, the attackers swiftly infiltrate your organization's system, bypassing security measures and infiltrating your valuable data assets. This alarming situation highlights the inherent risks associated with interconnected systems, where the security of one agency's infrastructure directly impacts the security posture of its partners. It serves as a stark reminder of the urgent need for comprehensive cybersecurity measures, stringent controls, and robust communication channels to minimize the potential fallout from breaches originating in connected agencies.

Introduction

In today's interconnected world, government agencies face a formidable challenge when it comes to safeguarding their sensitive data. With the increasing reliance on interconnections between agencies, as well as partnerships with external vendors and organizations, the security landscape becomes even more complex. As agencies strive to collaborate and exchange information seamlessly, they must grapple with the critical question: how can they protect their valuable data when it resides within someone else's system? Moreover, ensuring that systems connecting to their own infrastructure do not introduce unforeseen risks becomes a paramount concern. This blog post explores the strategies and frameworks, such as the NIST Risk Management Framework (RMF), OMB guidance, and other NIST special publications, that can empower agencies to fortify their cybersecurity posture and ensure compliance, even when systems outside their direct control are involved. By understanding the challenges and implementing robust security measures, agencies can proactively mitigate the potential risks associated with interconnections, ultimately safeguarding their vital assets from the ever-evolving threat landscape.

How the Federal Government Handles System Interconnections

The federal government has established a robust process that local governments can learn from and implement to enhance their cybersecurity practices. One crucial aspect of this process involves documenting how security controls are applied to a system through a comprehensive System Security Plan (SSP). A key element included in the SSP is the creation of an inventory or list of interconnections to the system. This inventory extends beyond software and hardware and encompasses vital data and connections to the system.

A recurring challenge arises for local governments when personnel changes occur within the organization, leading to a lack of knowledge regarding existing interconnections. This issue is particularly prevalent where the understanding of legacy infrastructure and connections may be fragmented or altogether lost. Consequently, critical situations can arise, such as incidents occurring without proper communication with connected agencies. By recognizing and addressing these challenges head-on, local governments can proactively adopt effective measures to document and manage interconnections, ensuring the integrity and security of their systems while fostering stronger collaboration with partner organizations.

Interagency connections require a comprehensive approach that goes beyond mere trust and cooperation. The key to establishing a solid foundation lies in having a formal agreement that outlines the necessary measures for protecting information, ensuring breach reporting protocols, and setting a defined timeframe for adherence. The federal government uses a Memorandum of Understanding (MOU) or Memorandum of Agreement (MOA), as a crucial document that serves as the legal framework for interagency collaborations. The MOU/MOA encapsulates three vital aspects: required levels of protection, mandatory breach reporting, and a specified timeframe for compliance. However, it doesn't stop there. To complement the legal aspect, an Interconnection Security Agreement (ISA) comes into play, providing the technical specifications and intricacies required for secure connections. Together, the MOU/MOA and ISA form a powerful duo, addressing both legal and technical aspects and paving the way for robust cybersecurity practices across interconnected systems. By implementing these formal agreements, agencies can establish a solid foundation, ensuring a shared understanding of security requirements and bolstering the overall resilience of interagency connections.

This documentation, including MOU/MOA, serves multiple purposes. Firstly, it establishes a clear mandate that systems outside the direct control of a system owner must adhere to the same level of protection for the shared data. By setting uniform requirements, the documentation ensures consistency and minimizes potential vulnerabilities arising from disparate security measures. Moreover, these formal agreements support mutual understanding among different system owners, fostering collaboration and shared responsibility. Additionally, such documentation offers a level of assurance to system owners, affirming that connected systems meet the necessary security requirements. By emphasizing the importance of formal documentation, organizations can fortify their cybersecurity posture, promote harmonization, and provide a solid foundation of trust and accountability within interagency connections.

Communication is Important

Regarding interagency cybersecurity, the vital role of effective communication between parties cannot be overstated. It is a linchpin for ensuring the ongoing maintenance and effectiveness of interconnections' security controls. By establishing clear communication channels, both sides can proactively notify each other about planned system changes that might impact the interconnection. This facilitates seamless change management activities and minimizes the risk of unintended disruptions or vulnerabilities. Additionally, robust communication protocols enable prompt and coordinated notification of security incidents and system disruptions. This timely exchange of information empowers both parties to respond swiftly and effectively, mitigating the impact of incidents and fostering a collaborative approach to incident response. (See NIST SP 800-100)

To explicitly address the subject of interconnecting information systems, it is essential to:

  • Establish formal agreements that outline the terms and conditions of the interconnection.

  • Clearly specify the technical and security requirements necessary for the interconnection.

  • Define the responsibilities and obligations of each participating organization involved in the interconnection.

  • Clearly specify the rules and guidelines governing the interconnections to ensure consistency and compliance.

  • Obtain written management authority prior to interconnecting any information systems, ensuring proper authorization and accountability.

Connection Lifecycle

The Connection Lifecycle, as outlined in NIST SP 800-47, provides a comprehensive approach to interconnecting information systems while prioritizing information security. This framework is recommended by OMB for federal systems, and it serves as an excellent guide for local governments as well. The lifecycle consists of four distinct phases, each with specific tasks and objectives. By following this lifecycle, organizations can effectively manage and secure interconnections, adhering to best practices and ensuring compliance with information security requirements.

Phase 1

  • Planning the interconnection

  • Establish a joint planning team

  • Define business case

  • Perform Certification & Accreditation on the system (federal-specific)

  • Determine interconnection requirements

  • Document interconnection agreement (MOU/MOA)

  • Approve or reject interconnection (management sign-off)

Phase 2

  • Establishing the interconnection

  • Develop implementation plan

  • Execute implementation plan

  • Activate interconnection

Phase 3

  • Maintaining the interconnection

  • Maintain the equipment

  • Manage users

  • Perform periodic security reviews

  • Analyze audit logs

  • Report and respond as needed

  • Contingency planning for disruptions

  • Change management process

  • Update and Maintain SSP as needed

Phase 4

  • Disconnecting the interconnection

  • Planned phase-out

  • Emergency disconnect

  • Restoration of interconnection

Assessments

When local governments connect with other systems, it is crucial to consider whether requiring an audit or accreditation of the connected system is necessary. While federal systems mandate this requirement through the Risk Management Framework (RMF), local governments must carefully assess the risks involved in interconnections. Unlike federal systems that benefit from connections with other authorized systems providing a level of assurance, local governments face the challenge of not knowing the current security controls or risk levels of external systems. In this context, evaluating the risk of connecting to another organization becomes essential. Requiring some form of assessment, such as an audit or authorization (formal accreditation), can provide valuable insights into the risk profile of the connected system. Armed with this information, local governments can make risk-based decisions regarding allowing or managing the connection, aligning their security practices with their risk appetite, and ensuring the overall integrity of their interconnected systems.

Timeliness

Timeliness is a critical factor when it comes to establishing secure interagency connections. These agreements play a pivotal role in ensuring that interconnections are executed only after the necessary agreements are in place. Importantly, the MOU/MOA includes provisions for prompt and timely notification in the event of a security breach, allowing for immediate action and response. Additionally, these agreements outline the steps to be taken if there is a breach of the established terms, enabling appropriate actions to address any breaches. Lastly, the MOU/MOA also includes provisions for cancellation, providing a mechanism for terminating the interconnection if needed.

Disconnection Issues

Disconnection can present complex challenges, particularly when another agency depends on the connection to your system. Disrupting the connection may have significant consequences, potentially impacting critical services they rely upon. It becomes imperative to have a well-defined agreement in place that outlines the process and conditions for disconnection and subsequent reconnection. Additionally, the agency relying on the connection should have a contingency plan in case of disruption. Redundant connections alone are not sufficient; considerations must extend beyond availability risks. Contemplating scenarios such as breaches or extended outages is crucial. How would such incidents impact operations, and what measures can be implemented to ensure continuity? Addressing these questions is essential to effectively manage disconnections and maintain uninterrupted operations while safeguarding vital services.

Applicability

Ensuring that all relevant issues are addressed in some form of agreement is essential. Various examples illustrate this approach:

  • Remote access can be adequately covered under the rules of behavior governing system usage.

  • Service-level agreements can define expectations and responsibilities regarding the level of service provided.

  • Maintenance agreements can outline the terms and conditions for ongoing system maintenance and support.

  • Contracts can encompass specific requirements and obligations between organizations.

By tailoring agreements to suit specific circumstances, organizations can effectively address critical issues without necessitating an MOU/MOA for every instance. The key is to ensure that all necessary aspects are properly documented, fostering clarity, accountability, and effective collaboration in interagency connections.

Effective Management of Agreements

Yes, there is a lifecycle for documents as well.

  • Agreements should have a defined end date, typically spanning a period of three years rather than being open-ended. This ensures that agreements are renewed and periodically reviewed and updated as needed.

  • Federal processes, such as the recertification process, mandate that agreements undergo thorough review and evaluation.

  • Local governments should also conduct periodic reviews of agreements, aligning them with system audits and assessments to maintain their relevance and effectiveness.

  • It is crucial to maintain regular communication with other parties involved in the agreement. Their environment may undergo changes, and they may not possess the same level of maturity in the agreement management process as your organization. Staying connected allows for timely adjustments and collaboration.

  • At times, changes in circumstances may necessitate modifications to the agreement. Flexibility should be maintained to accommodate these changes and ensure the agreement remains aligned with evolving requirements and objectives.

By adhering to these practices, organizations can effectively manage their agreements, promoting accountability, adaptability, and ongoing compliance in their interagency connections.

Discussion Questions

  • An interconnection between your system and an external system predates the accreditation of your system. What are some likely issues you will face in trying to implement an MOU/MOA on an existing connection?

  • How soon would you require notification from the owner of the interconnected system after they have had an incident?

  • How often should you contact the system owner of an interconnected system?

  • You contact the system owner of an interconnected system. No one at that organization seems to be aware of the MOU/MOA. What do you do?

Resources

NIST SP 800-47

NIST SP 800-100

NIST SP 800-37

NIST SP 800-53

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