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[This article is published in Public
Service Review: Home Office]
CESG is the National Technical Authority for Information
Assurance. Part of Government Communication Headquarters, CESG provides
advice, products and services to protect UK Government communication
and information systems. In this article CESG introduces the new Assurance
Model. This Model expresses CESG's whole-life approach to the management
of information risk and is designed to help both CESG and information
risk managers meet the challenges posed by the increasingly complex
Government ICT environment.
Information is important to any business. This is equally true for
Government and the public sector, which rely on accurate and timely
information to set policy and provide services. The Transformational
Government Strategy has been established to transform the business
of Government by making better use of information and communications
technology (ICT) for the delivery of the public services and policy
outcomes that impact on citizens' daily lives.
With such a revolution comes business risk. Risk should be managed
throughout the delivery of any change. However, with the growing reliance
of public sector organisations on information comes an increase in
the impact of the post-delivery failure of the operational information
infrastructure. Managing the risks to business information is known
as 'Information Assurance' (IA). IA gives us confidence that our information
systems will protect the information that they handle and will function
as they need to, when they need to, under the control of legitimate
users. This confidence is becoming increasingly important and IA is
an essential enabler of the Transformational Government vision, as
recognised by the 2007 UK National IA Strategy.
In recent years the focus for IA in Government has moved from those
Departments whose information was at greatest risk during the Cold
War to those Departments where the failure to protect information
assets would significantly impact on life within the UK. The needs
of these Departments are different, with many as concerned with the
reliability of and access to their information as they are with its
privacy.
Customer expectations have also changed. The growth of internet services
has led to an expectation that Government will provide services in
the same convenient, easy to use way. Under Transformational Government,
Departments must share information and data in order to achieve their
goals more than ever before. The use of information by Government
has become greater in scope, and the supporting ICT systems more complex
in nature. It is no longer possible to examine the risks associated
with an information-handling asset when it is commissioned and regard
that as sufficient.
The technology poses challenges too. ICT systems are no longer easily
defined or bounded, as interconnections and data sharing blur the
edges between the ICT of collaborating organisations. System improvements,
new users and software patching mean that configurations quickly move
away from the risk assessed base-line. Faster development times, frequent
software upgrades and shorter component life-cycles decrease the effectiveness
of 'traditional' product evaluations and accelerate the throughput
of new technologies and products.
It is to address these issues of need, expectation and complexity
that CESG is developing a new Assurance Model. The Model is CESG's
contribution towards addressing these challenges, and should help
those managing risks to do so in a more consistent and balanced fashion.
The Model is underpinned by four principles:
- that IA is an essential part of normal business risk management;
- that IA is a whole-life issue for information systems;
- that the responsibility for managing information risk is owned
by the data owner;
- that having a requirement for IA need not necessarily prescribe
specific risk mitigation activities.
The Model is for anyone who manages the technical risks to information
assets, whether they are a Departmental ICT system Accreditor, a product
manufacturer, or an ICT user. The Model can be used to identify alternative
ways of mitigating the impact or likelihood of a risk, or to provide
new sources of evidence in support of risk management. Ultimately
the Model expresses CESG's understanding that mitigations for information
risk exist across the life of an ICT solution and need not be exclusively
focussed on a single evaluation event in the life cycle.
The Model itself comprises four elements:
- those considerations associated with the concept, origin and
development of an ICT solution (Intrinsic);
- those considerations associated with the independent testing
of an ICT solution outside the development environment (Extrinsic);
- those considerations associated with the architecture of the
ICT solution and its integration with the business (Implementation);
- those considerations associated with an ICT solution that handles
'live' information or that is used or relied on by a business
(Operation).
By considering the mitigations for a risk across all of these elements
the risk managers or owners can build up a whole-life risk management
plan. This has the potential to increase their level of confidence
at less cost than would be the case were such mitigations to be 'bolted
on' later in the solutions life. More importantly, by taking an holistic
approach the risk manager can choose the most appropriate approach
to managing an information risk, balancing the needs of the business
for functionality with the needs of the business to manage the risks
to the integrity, availability and confidentiality of its information
asset. In providing a whole-life context to the risk owner the Model
can help to identify mitigations that may be better suited to current
business need - and business risk - than those that have traditionally
been relied on.
CESG is currently trialling the Model to increase its understanding
of what the Model means for the services that it provides to Government.
This is the first part of a major business change within CESG that
will see the Model - and its underpinning philosophy - made the foundation
to our service portfolio. CESG intends to make the Model central to
its engagement with Government and Industry stakeholders, since the
Model represents a philosophy that CESG believes is immediately accessible
to them. The project to trial the Model will complete later this year,
and the results and latest information will be made available to all
stakeholders and partners. If you would like more information on the
new CESG Assurance Model then please visit our web site at www.cesg.gov.uk.
The new CESG Assurance Model, showing the overlap between
the elements
and some of the factors from which risk mitigations can be derived.
Case study
A firewall is a simple component that controls accesses across an
IT network boundary. Without the Model an accreditor managing the
risks associated with a network connection might review the residual
risk, and determine that an assured product is needed, but no more.
Using the Model, however, the accreditor can acquire a broader set
of supporting information and might ask questions such as:
- How much trust will be needed in the supply chain, both now
and later? (Intrinsic, Operation)
- How will upgrades or patching be performed? (Intrinsic, Operation)
- Does the hardware or software need to be evaluated to mitigate
the risks, or would regular penetration testing be more appropriate?
(Extrinsic, Operation)
- Will the firewall be integrated into the business so its security
functions aren't degraded? (Implementation)
- Can the firewall be configured to support the access policies
that my business needs? (Intrinsic, Implementation)
- How will illicit access attempts be identified and what will
be done if they occur? (Implementation, Operation)
By considering the answers to such questions a product vendor or system
integrator might reduce or mitigate their delivery risks when seeking
to gain accreditation for an ICT solution and identify areas for design
improvements.
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