CTAS
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Background
Risk Management
Engagement
Scoping the evaluation
Evaluations
Assurance Maintenance
Further questions
Background
What is CTAS?
Why is CTAS required?
Who needs CTAS?
Can results of CTAS be
reused for other Customers?
What
is CTAS?
CTAS is an independent, technical security evaluation of a system
or product for a government department (or possibly a CNI) customer.
CTAS is carried out by approved evaluation companies with support
from CESG and results in advice on the extent to which technical risks
have been addressed. CTAS is designed to meet the needs of HMG Infosec
Standard 1(IS1) and equivalent documents like JSP440.
Evaluations focus on the technical security of systems, COTS products
and bespoke components within a system context. Procedures associated
with technical security can also be included within scope but evaluations
do not extend to an assessment of physical or personnel security.
It does not deal with cryptography as this is covered by the CAPS
scheme.
As far as availability is concerned, the evaluations can consider
resilience against malicious denial of service attacks, but in general
will not consider reliability or redundancy (although this might be
reviewed in future).
CTAS has been designed to allow a significant amount of flexibility
and evaluations can be tailored to meet the requirements of an Accreditor
but at the same time, certain minimum activities from the methodology
must always be carried out e.g. a review of the design and testing.
Why
is CTAS required?
CTAS exists in order to give technical advice to Customers on the
extent to which security risks have been addressed. As such, it will
not deliver a simple pass / fail result but is more likely to state
a degree of confidence in the effectiveness of intended security measures,
along with any residual security concerns or recommendations. However,
in some cases serious issues may result in a recommendation that the
product or system does not appear fit for its application for HMG/CNI.
Who
needs CTAS?
CTAS is only applicable for Customers in government departments
(or potentially in other parts of the Critical National Infrastructure).
The evaluation is paid for by a Sponsor, who may often be
a developer of the product or system or a service provider. (Note
that the terms for Customer and Sponsor can often
be confused). Can
results of CTAS be reused for other Customers?
In general, evaluations are tailored to the specific requirements
of individual Customers and the acceptance of a risk by one Customer
does not mean that it would necessarily be accepted by another. Therefore
the approval of a product or system based (in part) on CTAS advice,
does not necessarily mean that it can be used by other Customers.
However, some parts of an evaluation may be capable of re-use, subject
to appropriate rework agreed by the Accreditor. Another approach would
be to have a pan-government accreditation or multi-department accreditation
panel that makes approvals on behalf of a number of Customers.
Risk Management
What level of risk does CTAS address?
Who owns the risk?
How are risk levels determined?
What level of risk does CTAS address?
CTAS is primarily intended to address risks that would normally call
for an equivalent of Common Criteria at Evaluation Assurance Levels
in the range EAL2 - EAL4 for Impact Levels 2 to 4. For lower risks,
there may be alternative approaches including:
- CSIA Claims Tested Mark(CCTM)
- ISO/IEC 27001
- IT Health Checks
However, CTAS can also be used to address EAL1 in some cases i.e.
if the other approaches are not considered appropriate by the Customer.
In such instances, this can be discussed with CESG.
If the residual risk analysis indicates that a level equivalent to
EAL5 or higher is required, then CESG should be contacted to discuss
possible approaches. The contact details in this instance are: iacs@cesg.gsi.gov.uk.
Who
owns the risk?
The Customer ultimately owns the risk associated with an information
system. The Customer is typically an HMG department or possibly a
CNI organisation who procures or has procured the system or product.
The risk assessment may be delegated to an Accreditor.
Therefore a CTAS evaluation should never be seen as an approval
or accreditation of a product or system in itself. CTAS only provides
technical advice to departments for input to a risk management decision.
This is expected to be based on business needs and physical / personnel
security considerations in addition to the technical advice from
CTAS.
How
are risk levels determined?
The residual risk for an information system, product or component
is determined by following the procedures in IS1. Where risks cause
significant concern to a department, CTAS is one of a range of approaches
that can be used to gain further assurance.
Engagement
How is CTAS requested?
Who requests CTAS?
What happens when CESG is approached?
Who carries out the CTAS evaluations?
How do sponsors engage with CTAS evaluation companies?
Can CESG recommend a specific CTAS company?
How do CTAS evaluation companies engage with
CESG?
How
is CTAS requested?
CTAS is initiated by completing a questionnaire
(doc) . On receipt of this, CESG will advise whether the proposed
evaluation is appropriate and whether CESG will be able to support
an evaluation company in taking the work forward. The questionnaire
should be sent to iacs@cesg.gsi.gov.uk
Who
requests CTAS?
There must be a requirement from a Customer (in government or possibly
the wider CNI), however the request can also come from a developer
or service provider acting as a Sponsor (with the explicit support
of such a Customer).
What
happens when CESG is approached?
On receipt of a questionnaire, CESG will consider whether CTAS is
the best assurance service to match the requirements (this is not
always the case e.g. CAPS may be more appropriate in some cases) and
whether the proposal generally makes sense within a government security
context. In some cases, the Sponsor and Customer may be invited to
take part in further discussions with CESG to determine a way forward.
Who
carries out the CTAS evaluations?
CTAS evaluations can only be carried out by a limited number of companies
that have been approved to work on CESG's behalf. These specific 'CTAS
Evaluation Companies' are listed on the CESG website.
How do sponsors engage with CTAS evaluation companies?
Sponsors need to make their own arrangements for selecting and contracting
with CTAS companies to carry out the work.
Can CESG recommend a specific CTAS company?
No. All of the listed CTAS companies have been selected to meet the
required standard for the service and therefore CESG cannot recommend
a specific one. The only exception would be if some specialist expertise
was required or if there is the possibility of a conflict of interest.
In this case, specialist sub-contractors may be required that need
to be approved by CESG.
How do CTAS evaluation companies engage with CESG?
CTAS evaluation companies normally subcontract CESG to provide assurance
advice only on evaluations and to provide oversight of the CTAS scheme.
Optionally, CESG services may be contracted by the Customer to provide
assurance advice and oversight. The CTAS companies are to be used
for the actual evaluation testing. A Quick
Guide to Using the Service (pdf) is available on the CESG website.
Scoping
the evaluation
What is a Security Target?
Who is responsible for producing the Security Target?
How is the evaluation tailored?
What
is a Security Target?
A Security Target describes the scope of the system or product to
be evaluated (referencing design documents where appropriate), the
relevant threats and the claimed security functionality. The Security
Target needs to be produced and agreed before an evaluation can begin.
A Security Target template is included as an appendix to the CTAS
Methodology (pdf). Who is responsible for producing the Security Target?
The CTAS evaluation company is responsible for ensuring that a Security
Target has been produced but who actually produces it is not important.
The Security Target could in fact be written by the Customer, Sponsor,
CTAS evaluation company, CLAS Consultant, CLEF or by another party.
For example, the Sponsor may already have a draft Security Target
before they approach CTAS evaluation companies or they might ask the
evaluation company to produce a Security Target as part of the package
of work.
The Security Target must be agreed by key stakeholders (including
Accreditor and CESG) before the evaluation begins.
How is the evaluation tailored?
The appointed CTAS company will liaise with the Sponsor, the Customer,
Accreditor and CESG to agree the scope of work.
Based on the Security Target and the requirements of the Customer
and their Accreditor, an Evaluation Work Programme is produced by
the evaluation company. This will select the minimum required parts
of the CTAS methodology plus additional aspects as required by the
Accreditor (with advice from CESG where appropriate). An Evaluation
Work Programme template is included as an appendix to the CTAS
Methodology (pdf).
Evaluations
What takes place during software product evaluations?
What takes place during system evaluations?
What value does CESG add to the process?
What takes place during software product evaluations?
COTS products and bespoke components can be evaluated at one of two
levels, of which the first is considered roughly equivalent to EAL
2/3 and the second to EAL4. The CTAS Methodology gives more details
but the first level assesses overall confidence in the product by
considering available evidence in the following areas: functionality
and design, development procedures and basic security functional testing.
The second level supplements this with source code analysis and more
extensive vulnerability analysis.
What takes place during system evaluations?
The CTAS Methodology describes the approach in more detail. In essence
the evaluators review the architecture and design of the system, carry
out testing (normally including penetration testing) and can audit
operational procedures (as required by the Accreditor). Ongoing ‘assurance
maintenance’ is normally recommended for operational systems.
What value does CESG add to the process?
The bulk of work is carried out by the CTAS evaluation company. CESG’s
role is mainly to ensure that the companies maintain high standards
of work and to try and ensure a reasonably consistent approach between
companies. CESG will also advise on the scoping and approach of the
evaluation, will produce a summary of key recommendations and confirm
whether the agreed evaluation work was completed according to the
methodology.
In rare cases, CESG will offer in-house evaluation work to supplement
the CTAS evaluation but this will generally be handled by a separate
contract directly with the Customer.
Assurance
Maintenance
How is assurance maintained in Systems and Products?
What is an Assurance Maintenance Plan?
Who is responsible for producing an Assurance Maintenance Plan?
How is Assurance Maintenance initiated?
How is Assurance Maintenance tailored?
What takes place during the Assurance Maintenance Phase?
What is a Security Impact Analysis?
How is assurance maintained in Systems and Products?
Once an evaluation has been completed, it is likely that the system/product will be subject to change throughout its operational life. CESG recommends that changes are routinely assessed by an evaluation company to ensure that no security weaknesses are introduced during system upgrades. The CTAS Methodology describes the maintenance review and audit approach in more detail.
What is an Assurance Maintenance Plan?
An Assurance Maintenance Plan describes or references the procedures
for maintaining the assurance in the system or product as determined
in the previous CTAS evaluation and as updated by any subsequent assurance
activity. It covers procedures for change control, vulnerability awareness,
patching, testing and Maintenance Reviews. It also includes the planned
Maintenance Schedule.
Who is responsible for producing an Assurance Maintenance Plan?
The CTAS evaluation company is responsible for ensuring that an Assurance
Maintenance Plan has been produced but who actually produces it is
not important. The Assurance Maintenance Plan could in fact be written
by the Customer, Sponsor, CTAS evaluation company, CLAS Consultant,
CLEF or by another party. The Plan is normally produced during the
initial evaluation and should be agreed by key stakeholders (including
Accreditor and CESG) before the Maintenance Phase begins. It is then
subject to periodic review.
How is Assurance Maintenance initiated?
The assurance maintenance service is provided by the CTAS evaluation
companies, with appropriate assurance advice from CESG, and may be
covered by an extension to the original evaluation. Otherwise, the
engagement with a CTAS evaluation company and CESG is as described
for a CTAS evaluation.
How is Assurance Maintenance tailored?
The scope of the maintenance is normally that stated in the Security
Target and Evaluation Work Programme of the most recent related evaluation.
The assurance activities are derived from examining the changes summarised
in an outline Security Impact Analysis. Any major change to the original
security functionality may trigger a re-evaluation.
What takes place during the Assurance Maintenance Phase?
The CTAS Methodology describes the approach in more detail. In essence
the evaluators review proposed changes prior to implementation and
confirm whether they agree with the impact of the changes as summarised
in an outline Security Impact Analysis provided by the Developer.
A periodic Maintenance Review (e.g. annually) is later performed to
audit the correct implementation of these changes. The latter review
may include a check for new vulnerabilities, a review of the patches
applied, an audit of maintenance procedures, a review of Developer
testing and a test of updated security functionality.
What is a Security Impact Analysis?
A Security Impact Analysis (SIA) describes all changes between specific
versions of the system or product and categorises each change as having
major or minor security relevance. The SIA summarises the impact of
each change on the previous evaluation deliverables, stating which
deliverables need to be updated and justifying whether a re-evaluation
or maintenance audit is appropriate. The SIA, together with guidance
on categorising changes, is described in an appendix to the CTAS
Methodology (pdf).
Further
questions
Where is more information about CTAS?
The CESG website (www.cesg.gov.uk)
contains further information including a Quick
Guide to Using the Service (pdf). In particular, please consult
the current versions of the CTAS Methodology
document (pdf) and the CTAS
Operational Procedures (pdf) document for definitive guidance. |