A.5 Additional Information
Additional information is provided in the following sections:
5.1 Risk Impact Evaluation Criteria. These are the criteria we used to evaluate the impact of risks on critical assets.
5.2 Other Assets. This list includes all of the assets identified as important during processes 1 to 3 of the OCTAVE Method.
5.3 Security Practice Survey Results. These are a complete set of results from the security practice surveys and follow-up discussions completed during processes 1 to 3 of the OCTAVE Method.
A.5.1 Risk Impact Evaluation Criteria
We defined the impact evaluation criteria and then evaluated each impact against those criteria. We recommend that these evaluation criteria, shown in Table A-22, become a standard for MedSite. We include criteria for the following areas:
Table A-22. Evaluation Criteria
Reputation/ customer confidence |
Reputation irrevocably destroyed or damaged
Loss of rating or accreditation by review organizations
More than 30 percent drop in customers due to loss of confidence
|
Reputation damaged; some effort and expense required to recover
Reduction or warning of reduction of rating or accreditation by authorizing organizations
Drop in customers of 10 to 30 percent due to loss of confidence
Public violations of Privacy Act: (1) disclosure to personnel within the medical treatment facility without the need to know; (2) anyone who violates the Privacy Act and reveals sensitive medical information
Patient driven to seek care from another source
|
Reputation minimally affected; little or no effort or expense required to recover
No change in rating or accreditation by authorizing organizations
Less than 10 percent drop in customers due to loss of confidence
Nonpublic violation of Privacy Act (disclosure to personnel within the medical treatment facility with a need to know—trusted agent)
|
Life/health of customers |
Loss of customer life
Permanent impairment of one or more significant aspects of customer's health (e.g., loss of use of one or more limbs, blindness, brain damage)
Inability to provide patient care for more than a week
Safety violated
|
Customer life threatened but recoverable with additional treatment
Temporary or recoverable impairment of customer's health (e.g., recovering use of limbs through physical therapy)
Inability to provide patient care for one to two days
Safety affected
|
No loss or significant threat to customer life
Minimal, immediately treatable degradation in customer health with recovery within four days
Continuity of care requiring increased communication between providers at different facilities
Safety questioned
|
Productivity |
Physicians and/or nursing staff unable to perform critical job aspects for two or more days (e.g., no surgery, physical therapy, specialized patient care)
Increase in work hours of 40 percent or more required of at least 10 percent of general staff for >two days (e.g., manual re-creation of treatment records or manual correlation of lab results and plans)
Irrecoverable loss of patient records/information
|
Physicians and/or nursing staff work increased by 10 to 40 percent for one day (e.g., locating paper records, verifying all decisions verbally); inability to access test or lab results
Increases in general staff work of 10 to 40 percent for one day (e.g., duplicating written records, re-creating patient billing records, retrieving and verifying backup data)
Inefficient continuity of care; delays while recovering misplaced information
|
Physicians and/or nursing staff inconvenienced for less than a day but no measurable increase in work effort required (e.g., appointments delayed by hours, lab to be called for results)
General staff inconvenienced for less than a day but no measurable increase in work effort required
|
Fines/legal penalties |
Fines of greater than $100,000 levied
One or more nonfrivolous lawsuits of more than $3 million filed by customers
High-profile, in-depth investigation into organizational practices initiated by government or other investigative organization
|
Fines of $10,000 to $100,000 levied
One or more nonfrivolous lawsuits between $250,000 and $3 million filed by customer
Information or records (low-profile) requested by government or other investigative organization
|
No fine or a fine of less than $10,000 levied
Lawsuits of less than $250,000 or frivolous lawsuit (95 percent probability of defeat) filed by customers
No queries from government or other investigative organizations
|
Finances |
Yearly operational costs up 15 percent (e.g., using temps for records recovery, adding software to deter further intrusions)
Revenue loss of 20 percent yearly (e.g., relocating 20 percent of patients to other sites due to power loss)
Onetime financial cost >$1 million (e.g., replacing system damaged by water, hiring 25 temps to reenter records)
Irredeemable errors in funding and personnel
|
Yearly operational costs up 2 to 15 percent (e.g., hiring temps for three months to hand-carry labor results several times a day)
Revenue loss of 5 to 20 percent yearly (e.g., delaying profitable surgeries due to file loss and recovery)
Onetime financial cost of $25,000 to $1 million (e.g., adding a server and reallocating assets)
Partially redeemable errors in funding and personnel
|
Increase of less than 2 percent in operating costs (e.g., one week of overtime for four staff members to document changes in treatment plans)
Revenue loss of <5 percent yearly (e.g., $50,000 research funds if no remote university access)
Onetime financial cost of <$25,000 (e.g., retraining 20 staff members)
Inconvenient but redeemable errors in funding and personnel
|
Other (facilities) |
|
Damage to a facility or building requiring temporary relocation of patients
Inability to verify credentials of providers or medical staff
Inability to track performance of facilities or providers accurately
|
|
A.5.2 Other Assets
The complete list of assets identified by personnel during processes 1 to 3 is shown in Table A-23. This list of assets highlights differences in opinion about what is important to MedSite. We recommend that any additional work with respect to documenting MedSite's information-related assets should start with this list.
Table A-23. Assets Grouped by Organizational Level
Senior managers (process 1) |
|
Emergency Care Data System (ECDS)
Email
Personnel management system
Internet connectivity
Medical Logistics System (MLS)
|
Operational area managers (process 2) |
Paper medical records
PIDS
ECDS
|
Pharmacy system
Medical logistics system
Providers' credentials
|
Staff members (process 3) |
Paper medical records
PIDS
External relations
Email (PIDS and general)
|
|
IT staff members (process 3) |
ABC Systems
Internet connectivity
MedSite help desk
All servers
|
|
A.5.3 Consolidated Survey Results
Tables A-24 through A-41 contain the following information:
We organized all results according to strategic and organizational practice areas contained in the OCTAVE catalog of practices. The following list describes how to interpret the survey results:
Yes:
75 percent or more of respondents answered that the practice is most likely used by the organization.
No:
75 percent or more of respondents answered that the practice is most likely not used by the organization.
Unclear:
Based on the respondents' answers, it is not clear whether the practice is used by the organization.
Current Strategic Practices of MedSite
Table A-24. Security Awareness and Training
Survey Statement |
Senior Managers |
Operational Area Managers |
Staff |
IT Staff |
Staff members understand their security roles and responsibilities. This is documented and verified. |
Yes |
No |
No |
Unclear |
There is adequate in-house expertise for all supported services, mechanisms, and technologies (e.g., logging, monitoring, or encryption), including their secure operation. This is documented and verified. |
Unclear |
Yes |
Unclear |
Unclear |
Security awareness, training, and periodic reminders are provided for all personnel. Staff understanding is documented and conformance is periodically verified. |
Unclear |
Unclear |
Unclear |
Unclear |
Organizational Level |
Protection Strategy Practices |
Organizational Vulnerabilities |
Senior management |
We have training, guidance, regulations, and policies. |
Personnel understand systems, but not incident management and/or recognizing and reporting anomalies. |
Operational area management |
Awareness training is required to gain account/access. |
IT personnel are inadequately trained. Staff do not understand security issues. |
Staff |
|
Whom do you call with a problem? Who is responsible? There is weakness in the training as it relates to PIDS, medical records, and other systems.
I do not understand my role or responsibility for security.
|
IT staff |
Security awareness training is carried out 100 percent. |
Awareness training is inadequate. |
Table A-25. Security Strategy
Survey Statement |
Senior Managers |
Operational Area Managers |
Staff |
IT Staff |
The organization's business strategies routinely incorporate security considerations. |
No |
Unclear |
|
No |
Security strategies and policies take into consideration the organization's business strategies and goals. |
Unclear |
Unclear |
|
No |
Security strategies, goals, and objectives are documented and are routinely reviewed, updated, and communicated to the organization. |
Yes |
Unclear |
|
No |
Organizational Level |
Protection Strategy Practices |
Organizational Vulnerabilities |
Senior managers |
|
We lack business sense, and do not have a proactive philosophy. |
Operational area managers |
|
Current protection strategy ineffective. |
Staff |
|
|
IT staff |
|
There is a lack of exposure to end-user activity. |
Table A-26. Security Management
Survey Statement |
Senior Managers |
Operational Area Managers |
Staff |
IT Staff |
Management allocates sufficient funds and resources to information security activities. |
Yes |
Yes |
Unclear |
No |
Security roles and responsibilities are defined for all staff in the organization. |
Yes |
Yes |
Unclear |
Unclear |
The organization's hiring and termination practices for staff take information security issues into account. |
Unclear |
Yes |
Unclear |
Unclear |
The organization manages information security risks by (1) assessing existing risks to information security and (2) taking steps to mitigate information security risks |
No |
No |
Unclear |
Unclear |
Management receives and acts upon routine reports summarizing security-related information (e.g., audits, logs, risk and vulnerability assessments). |
No |
Unclear |
|
No |
Organizational Level |
Protection Strategy Practices |
Organizational Vulnerabilities |
Senior management |
We are doing this risk evaluation, so that's a start. |
I don't think we actually get those kind of reports; maybe we should. |
Operational area management |
|
I'm concerned about complacency—we've been very lucky so far. |
Staff |
|
|
IT staff |
|
Budget and staff are inadequate.
Equipment and software are out of date.
|
Table A-27. Security Policies and Regulations
Survey Statement |
Senior Managers |
Operational Area Managers |
Staff |
IT Staff |
The organization has a comprehensive set of documented, current policies that are periodically reviewed and updated. |
Yes |
Yes |
Unclear |
Yes |
There is a documented process for management of security policies:
Creation
Administration (including periodic reviews and updates)
Communication
|
Yes |
Yes |
Unclear |
Unclear |
The organization has a documented process for evaluating and ensuring compliance with information security policies, applicable laws and regulations, and insurance requirements. |
Yes |
Yes |
|
No |
The organization uniformly enforces its security policies. |
Unclear |
No |
No |
No |
Organizational Level |
Protection Strategy Practices |
Organizational Vulnerabilities |
Senior management |
Policies and procedures exist.Training guidance and regulations exist. |
Consequences, or lack thereof, for violating policies and procedures are not well known; we're not enforcing our own policies. |
Operational area management |
People know whom to call when a security incident occurs. |
People don't always read or follow policies and procedures. |
Staff |
|
Policies are poorly communicated. |
IT Staff |
There are established incident-handling policies and procedures. |
Follow-up on reported violations of security procedures is lacking. IT staff are unable to enforce procedures. |
Table A-28. Collaborative Security Management
Collaborative Security Management: Survey Results |
Survey Statement |
Senior Managers |
Operational Area Managers |
Staff |
IT Staff |
The organization has policies and procedures for protecting information when working with external organizations (e.g., third parties, collaborators, subcontractors, or partners):
Protecting information belonging to other organizations
Understanding the security policies and procedures of external organizations
Ending access to information by terminated external personnel
|
Yes |
Yes |
Unclear |
Yes |
The organization has verified that outsourced security services, mechanisms, and technologies meet its needs and requirements. |
Unclear |
Unclear |
|
No |
Organizational Level |
Protection Strategy Practices |
Organizational Vulnerabilities |
Senior management |
|
There is distributed management of PIDS, and lack of centralized control. |
Operational area management |
|
We rely on multiple organizations to support our networks. |
Staff |
|
|
IT staff |
ABC Systems is responsible for security on its systems and networks; their staff are using good security practices (have a firewall, running Crack, etc.) |
There is no single focal point for connectivity. Things get confused sometimes. |
Table A-29. Contingency Planning/Disaster Recovery
Survey Statement |
Senior Managers |
Operational Area Managers |
Staff |
IT Staff |
An analysis of operations, applications, and data criticality has been performed. |
Yes |
Unclear |
|
Unclear |
The organization has documented, reviewed, and tested business continuity or emergency operation plans, disaster recovery plan(s), and contingency plan(s) for responding to emergencies. |
No |
Unclear |
|
Unclear |
The contingency, disaster recovery, and business continuity plans consider physical and electronic access requirements and controls. |
No |
No |
|
No |
All staff are aware of the contingency, disaster recovery, and business continuity plans and understand and are able to carry out their responsibilities. |
Yes |
Unclear |
No |
Unclear |
Organizational Level |
Protection Strategy Practices |
Organizational Vulnerabilities |
Senior management |
We do have a disaster recovery plans for natural disasters and some emergencies. |
We don't have a business continuity plan. |
Operational area management |
|
Business continuity and disaster recovery plans are lacking. |
Staff |
|
I'm sure we have them, but I've never seen them and I'm not sure what I'm supposed to do. |
IT staff |
|
Contingency plans if the network stays down or we lose the servers are lacking. |
Current Operational Practices of MedSite
Table A-30. Physical Security Plans and Procedures
Survey Statement |
Senior Managers |
Operational Area Managers |
Staff |
IT Staff |
Facility security plans and procedures for safeguarding the premises, buildings, and any restricted areas are documented and tested. |
Unclear |
Unclear |
Unclear |
No |
There are documented policies and proce for managing visitors. |
Yes |
Yes |
Unclear |
Yes |
There are documented policies and proceduresdures for physical control of hardware and software. |
Yes |
Yes |
Unclear |
Yes |
Organizational Level |
Protection Strategy Practices |
Organizational Vulnerabilities |
Senior management |
|
I'm not sure how often the plans are tested. |
Operational area management |
|
There is little challenging of people after hours.
Once sensitive data are printed and distributed, they are not properly controlled or handled.
|
Staff |
|
If someone enters through the emergency room entrance, he or she can get anywhere. Storage space for sensitive information is insufficient. |
IT staff |
Hardware security is very good. |
|
Table A-31. Physical Access Control
Survey Statement |
Senior Managers |
Operational Area Managers |
Staff |
IT Staff |
There are documented policies and procedures for controlling physical access to work areas and hardware (computers, communication devices, etc.) and software media. |
Yes |
Yes |
Unclear |
Unclear |
Workstations and other components that allow access to sensitive information are physically safeguarded to prevent unauthorized access. |
Yes |
Yes |
No |
Yes |
Organizational Level |
Protection Strategy Practices |
Organizational Vulnerabilities |
Senior management |
|
|
Operational area management |
|
|
Staff |
We are required to lock up our offices at the end of the day. |
Physical security is hampered by
Location/distribution of terminals
The need to share terminals
Shared office space
Shared codes to cipher locks
Multiple access points to rooms
|
IT staff |
Hardware security is very good. |
|
Table A-32. Monitoring and Auditing Physical Security
Survey Statement |
Senior Managers |
Operational Area Managers |
Staff |
IT Staff |
Maintenance records are kept to document the repairs and modifications of a facility's physical components. |
|
|
|
Yes |
An individual's or group's actions can be accounted for with respect to all physically controlled media. |
|
|
|
No |
Audit and monitoring records are routinelyexamined for anomalies, and corrective action is taken as needed. |
|
Unclear |
|
No |
Organizational Level |
Protection Strategy Practices |
Organizational Vulnerabilities |
Senior management |
|
|
Operational area management |
|
I have never actually seen an overall audit report on maintenance and repairs. |
Staff |
|
|
IT staff |
|
We track repairs and modifications.
Audit records are spotty. I'm not sure we ever review them.
|
Table A-33. System and Network Management
Survey Statement |
Senior Managers |
Operational Area Managers |
Staff |
IT Staff |
There are documented and tested security plan(s) for safeguarding the systems and networks. |
Yes |
Unclear |
|
No |
Sensitive information is protected by secure storage (e.g., backups stored off-site, discard process for sensitive information). |
|
|
|
Yes |
The integrity of installed software is regularly verified |
|
|
|
Yes |
All systems are up to date with respect to revisions, patches, and recommendations in security advisories. |
|
|
|
Unclear |
There is a documented and tested data backup plan for backups of both software and data. All staff understand their responsibilities under the backup plans. |
Yes |
Unclear |
No |
Yes |
Changes to IT hardware and software are planned, controlled, and documented. |
|
|
|
Yes |
IT staff members follow procedures when issuing, changing, and terminating users' passwords, accounts, and privileges.
Unique user identification is required for all information system users, including third-party users.
Default accounts and default passwords have been removed from systems.
|
|
|
|
Yes |
Only necessary services are running on systems; all unnecessary services have been removed. |
|
|
|
Unclear |
Organizational Level |
Protection Strategy Practices |
Organizational Vulnerabilities |
Senior management |
There is a security plan. ABC Systems has one. |
|
Operational area management |
|
I'm not sure the people outside IT understand they have responsibilities. |
Staff |
|
|
IT staff |
We know what we're supposed to do.
ABC Systems does all of the virus and vulnerability checking. Their people send us the results.
Systems are well protected with passwords, authorizations, etc.
We force users to change passwords regularly.
ABC Systems has reported very few intrusions.
|
There's no documented plan.
ABC Systems must keep up to date with security notices, but I'm not sure.
I don't think we clean up inherited access rights very well. One of the managers brought a database system down last week with access rights he should not have had. We are looking into that.
|
Table A-34. System Administration Tools
Survey Statement |
Senior Managers |
Operational Area Managers |
Staff |
IT Staff |
Tools and mechanisms for secure system and network administration are used, and they are routinely reviewed and updated or replaced. |
|
|
|
Unclear |
Organizational Level |
Protection Strategy Practices |
Organizational Vulnerabilities |
Senior management |
|
|
Operational area management |
|
|
Staff |
|
|
IT staff |
ABC Systems is supposed to run most of these tools from its site. |
We run some of them and are supposed to get updated versions and training, but that hasn't happened lately. |
Table A-35. Monitoring and Auditing IT Security
Survey Statement |
Senior Managers |
Operational Area Managers |
Staff |
IT Staff |
System and network monitoring and auditing tools are routinely used by the organization. Unusual activity is dealt with according to the appropriate policy or procedure. |
|
|
|
Unclear |
Firewall and other security components are periodically audited for compliance with policy. |
|
|
|
Yes |
Organizational Level |
Protection Strategy Practices |
Organizational Vulnerabilities |
Senior management |
|
|
Operational are management |
|
|
Staff |
|
|
IT staff |
ABC Systems does all of the audits and runs monitoring tools. |
I don't think ABC Systems reports unusual activity to anyone here, and I'm not sure if the response is according to our policy or ABC's. |
Table A-36. Authentication and Authorization
Survey Statement |
Senior Managers |
Operational Area Managers |
Staff |
IT Staff |
Appropriate access controls and user authentication (e.g., file permissions, network configuration) consistent with policy are used to restrict user access to information, sensitive systems, specific applications and services, and network connections. |
|
Unclear |
|
Yes |
There are documented policies and procedures to establish and terminate the right of access to information for both individuals and groups. |
Yes |
Yes |
|
Yes |
Methods or mechanisms are in place to ensure that sensitive information has not been accessed, altered, or destroyed in an unauthorized manner. Methods or mechanisms are periodically reviewed and verified. |
|
|
|
Yes |
Organizational Level |
Protection Strategy Practices |
Organizational Vulnerabilities |
Senior management |
|
|
Operational area management |
There are policies for access control and permissions. |
But we're not using role-based management of accounts, and people inherit far too many privileges. |
Staff |
|
|
IT staff |
Systems are well protected with passwords, authorizations, etc. |
|
Table A-37. Vulnerability Management
Survey Statement |
Senior Managers |
Operational Area Managers |
Staff |
IT Staff |
There is a documented set of procedures for managing vulnerabilities:
Selecting vulnerability evaluation tools, checklists, and scripts
Keeping up to date with known vulnerability types and attack methods
Reviewing sources of information on vulnerability announcements, security alerts, and notices
Identifying infrastructure components to be evaluated
Scheduling vulnerability evaluations
Interpreting and responding to the results
Maintaining secure storage and disposition of vulnerability data
|
|
|
|
Unclear |
Vulnerability management procedures are followed and are periodically reviewed and updated. |
|
|
|
Unclear |
Technology vulnerability assessments are performed on a periodic basis, and vulner-abilities are addressed when they are identified. |
|
|
|
Unclear |
Organizational Level |
Protection Strategy Practices |
Organizational Vulnerabilities |
Senior management |
|
|
Operational area management |
|
|
Staff |
|
|
IT staff |
ABC Systems does all of the vulnerabilitymanagement and assessment activities. They do a good job. |
We haven't been trained in what to do with those vulnerability reports. We usually file them in a drawer. |
Table A-38. Encryption
Survey Statement |
Senior Managers |
Operational Area Managers |
Staff |
IT Staff |
Appropriate security controls are used to protect sensitive information while in storage and during transmission (e.g., data encryption, public key infrastructure, virtual private network technology). |
|
|
|
Yes |
Encrypted protocols are used for remote management of systems, routers, and firewalls. |
|
|
|
Yes |
None Provided |
Table A-39. Security Architecture and Design
Security Architecture and Design |
Survey Statement |
Senior Managers |
Operational Area Managers |
Staff |
IT Staff |
System architecture and design for new and revised systems include considerations for:
Security strategies, policies, and procedures
History of security compromises
Results of security risk assessments
|
|
|
|
Unclear |
The organization has up-to-date diagrams that show the enterprisewide security architecture and network topology. |
|
|
|
Yes |
Organizational Level |
Protection Strategy Practices |
Organizational Vulnerabilities |
Senior management |
|
|
Operational area management |
|
|
Staff |
|
|
IT staff |
|
They're already building PIDS II, but no one ever talked to us about its security needs. Maybe ABC Systems already knows. |
Table A-40. Incident Management
Survey Statement |
Senior Managers |
Operational Area Managers |
Staff |
IT Staff |
Documented procedures exist for identifying, reporting, and responding to suspected security incidents and violations. |
Yes |
Unclear |
Unclear |
Yes |
Incident management procedures are periodically tested, verified, and updated. |
Unclear |
No |
Unclear |
No |
There are documented policies and procedures for working with law enforcement agencies. |
No |
No |
No |
Unclear |
Organizational Level |
Protection Strategy Practices |
Organizational Vulnerabilities |
Senior management |
|
I never even considered dealing with law enforcement for security problems until just now. |
Operational area management |
Procedures exist for incident response. |
Not everyone is aware of the procedures. |
Staff |
|
I don't know if I'm supposed to do anything or what to look for. Whom do we call? |
IT staff |
|
I suppose we should call law enforcement if the system really gets attacked. But do we call, or does ABC Systems? |
Table A-41. General Staff Practices
Survey Statement |
Senior Managers |
Operational Area Managers |
Staff |
IT Staff |
Staff members follow good security practice as by doing the following:
Securing information for which they are responsible
Not divulging sensitive information to others (resistance to social engineering)
Ensuring they have adequate ability to use information technology hardware and software
Using good password practices
Understanding and following security policies and regulations
Recognizing and reporting incidents
|
Unclear |
Unclear |
No |
Yes |
All staff at all levels of responsibility implement their assigned roles and take responsibility for information security. |
Unclear |
No |
Unclear |
Yes |
There are documented procedures for authorizing and overseeing all staff (including personnel from third-party organizations) who work with sensitive information or in locations where the information resides. |
Yes |
Unclear |
No |
Yes |
Organizational Level |
Protection Strategy Practices |
Organizational Vulnerabilities |
Senior management |
|
I'm fairly certain people share passwords and accounts. |
Operational area management |
|
They have so much trouble logging in and out and moving between machines that they just don't bother. |
Staff |
We get "don't share passwords" type of training. |
Physical layouts, insufficient equipment, and cramped space all lead to sharing of passwords, accounts, machines, whatever. We all trust each other. |
IT staff |
All staff are trained on passwords. |
|
|