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GUIDANCE
System Process Flowchart / Information Systems Security (Revised 07/2003)

Information Systems Security (ISS) Policy. The FAA is required by law, Federal Information Security Management Act of 2002 (FISMA), OMB Circular A-130, and other federal standards to provide security for all agency information that is collected, stored, processed, disseminated, or transmitted using agency or non-agency owned information systems. ISS measures ensure that the correct functioning of information processing systems is protected from threats to integrity, availability, and confidentiality. FAA has relatively few information systems which process "classified" information (i.e., information related to national security). However, almost all agency information systems, including the Air Traffic Management system, process "sensitive" information subject to federal information security requirements. Sensitive information is information that if disclosed, altered, forged, or rendered unavailable or unreliable, could result in any of the following:

  • Seriously inhibited system operation;
  • Serious and widespread delays;
  • Damage to the public perception of Air Traffic Control; or
  • Expenditure of significant resources by the FAA or users to reestablish NAS operations;
  • Be an unwarranted invasion of personal privacy;
  • Reveal a trade secret or privileged or confidential commercial or financial information;
  • Be detrimental to the security of transportation.

Given the broad scope of legislation and FAA policy requirements, ISS is a principal concern for virtually every acquisition program, both operational and administrative.
Two-Track Approach for Achieving Information Systems Security. The FAA has a two-track approach for achieving agency-wide information security. First, there is a focused effort to develop economy of scale ISS standards for all information systems in the NAS. A-ll NAS face similar threats and require protection. Otherwise, in such a highly interconnected "system of systems" as the NAS, a threat whose attack is unsuccessful in one area could simply move on to another. Second, individual systems are designed to be compliant with NAS ISS standards, while at the same time being tailored to design requirements and security vulnerabilities that may be highly system-specific.

The second set of activities are intended to ensure individual systems are compliant with NAS Technical Architecture standards and tailored to specific vulnerabilities and system design features. ISS activities occur throughout the acquisition management lifecycle, and are especially important in the early phases when requirements are defined and acquisition programs are initiated. Activity begins in earnest during Investment Analysis, when the Requirements Document (RD) is defined and candidate solutions are developed sufficiently to establish cost, schedule, performance, and benefits baselines. ISS requirements and costs must be included in these documents. During Solution Implementation, actual hardware, software, and facility components are designed and acquired that satisfy ISS requirements. The new capability is tested at the end of Solution Implementation to compliance with ISS requirements. When the system is certified as ISS-compliant, it becomes eligible for an In-Service Decision. During In-Service Management, ISS activities focus on maintaining and operating systems to minimize information security concerns, and on upgrading performance as needed for protection against emerging or previously undefended vulnerabilities. In particular, COTS products often harbor ISS vulnerabilities that are discovered only after the products are released. All COTS product vendors must be continuously monitored for announcement of these vulnerabilities, and appropriate corrections must be implemented according to vendor recommendations. In some instances, product upgrades may be developed as new threats are identified .
The FAA ISS Program policy is contained in FAA Order 1370.82, as amended (intranet.faa.gov/aio). This order supersedes FAA Order 1600.54B (FAA Automated Information System Security Handbook). For additional information regarding ISS policy and guidance, Contact AIS-1. The FAA Certification and Accreditation Program policy contained in the FAA ISS Handbook, . For more information contact AIS-300.
The following activities are executed during the AMS lifecycle management process so that appropriately secure information systems are acquired and operated.

ISS Work Activities During Investment Analysis

 

Activity: Gain Familiarity with ISS Elements of NAS Technical Architecture
ISS-1

Responsible
Agent

Product

Approval
Authority

Tools and Aids

Security systems engineering member of the Investment Analysis Team

     
Description:
The Investment Analysis Team must be thoroughly familiar with Information System Security elements of the NAS Technical Architecture. This architecture constitutes the "baseline" of existing and planned FAA capability, and contains the transition plan for reaching the future NAS configuration.



Activity: Gain Familiarity with FAA Security Policy and Process
ISS-2

Responsible
Agent

Product

Approval
Authority

Tools and Aids

Security systems engineering member of the Investment Analysis Team

    ISS Policy, FAA Order 1370.82 

ISS Handbook  (Intranet Only)

NIST Special Pub 800-12 (et al)

Description:
The Investment Analysis Team must become thoroughly familiar with Information System Security Policy ( Order 1370.82) and the ISS Process Handbook, and applicable guidance and standards issued by the National Institute of Standards and Technology (NIST) in fulfillment of their responsibilities specified in FISMA. As Investment Analysis proceeds, the Investment Analysis Team uses these processes to tailor ISS requirements for the candidate solutions under consideration.


Activity: Conduct or Receive a Threat Stipulation
ISS-3

Responsible
Agent

Product

Approval
Authority

Tools and Aids

Office of  Security & Investigations and Office of Information Systems Security

Threat Stipulation

Designated Approving Authority, ISS Manager, Certification and Accreditation Agent (AIS-300 for AIS-1), Product Team Lead, and a system end-user representative

ISS Handbook,  

FAA NAS System Protection Profile

 
Description:
The Office of  Security & Investigations (ASI) provides a  physical and personnel security "Threat Stipulation" for all FAA and NAS information systems. The "Threat Stipulation" is an intelligence assessment. It addresses the likely threats to FAA information systems (i.e., those persons or organizations deemed likely to have a motive to attack FAA/NAS systems) and the likely  mechanisms that these threats could use. Be sure to contact ASI to determine what needs to be done.  The Office of Information Systems Security (AIS) provides guidance on cyber-threats to FAA information systems and how to address them in risk analysis and system requirements.


Activity: Interpret / Tailor Security Policy and Requirements
ISS-4

Responsible
Agent

Product

Approval
Authority

Tools and Aids

Security systems engineering member of the Investment Analysis Team with support from the Office of Information Systems  Security

ISS requirements for candidate solutions

Line of Business ISSM and AIS- 300

 

ISS Handbook   

FAA NAS System Protection Profile

 

Description:
Based on the Threat Stipulation, the Investment Analysis Team tailors Information System Security requirements and drafts candidate solutions to be evaluated. The nature of the tailoring depends on:

  • The anticipated user community (e.g., FAA users only or other government or non-government users);
  • The relative sensitivity of the information and functionality being threatened (e.g., highly sensitive or innocuous); 
  • The system architecture and intended platform safeguards; and
  • Pertinent ISS environmental factors (e.g., power reliability problems).


Activity: Incorporate ISS Requirements into Initial Requirements Document
ISS-5

Responsible
Agent

Product

Approval
Authority

Tools and Aids

Security systems engineering member of the Investment Analysis Team

ISS requirements for the initial Requirements Document

ISSM, PTL

ISS Handbook   

FAA NAS System Protection Profile 

NIST SP 800-30 Security Risk Management

Systems Engineering Manual Section 4.10 Risk Management

Description:
The Investment Analysis Team works with the Sponsoring organization to incorporate preliminary Information System Security requirements in the Initial Requirements Document. These initial requirements are the basis for development and evaluation of alternative solutions to mission need. At this stage, ISS requirements may be high-level and incomplete, but they must reflect the security of the FAA.  Section 3 of the NAS System Protection Profile provides security objectives which must be considered in association with the high level system design and potential vulnerabilities and threats.


Activity: Evaluate ISS Capability of Candidate Solutions to Mission Need
ISS-6

Responsible
Agent

Product

Approval
Authority

Tools and Aids

Security systems engineering member of the Investment Analysis Team

Evaluation of the ISS capability of candidate solutions to mission need

 

ISS Handbook

NIST SP 800-12 NIST Computer Security Handbook

Description:
The Investment Analysis Team defines, analyzes, and evaluates a number of candidate solutions to mission need during Investment Analysis. As part of this evaluation, the Investment Analysis Team develops an Information System Security technical description of hardware, software, and communications in sufficient detail to allow potential vulnerabilities to be identified and assessed.

Evaluating the ISS capability of each candidate solution involves the following four steps which are described in detail in the ISS Handbook, :

  • Vulnerability identification and assessment,
  • Risk assessment,
  • Risk mitigation plan,
  • Residual risk assessment
These steps are conducted to the appropriate level of detail which is less than the vendor will perform during Solution Implementation, but sufficient to gain confidence in the ISS capability of each candidate solution to meet the security requirements developed in the Initial Requirements Documents (ISS-6).

 



Activity: Incorporate ISS Requirements into Final Requirements Documents
ISS-7

Responsible
Agent

Product

Approval
Authority

Tools and Aids

IAT systems engineering specialist with assistance by the Office of  Security & Investigations and Office of Information Systems Security

Final ISS requirements for each candidate solution Residual Risk Assessment

ISSM, AIS-300

ISS Handbook

FAA NAS System Protection Profile

NIST SP 800-30 Security Risk Management  

FAA Systems Engineering Manual Section 4.10 Risk Program

Description:
By the end of the Investment Analysis, the Investment Analysis Team will have defined a set of final requirements (including Information System Security requirements) for each candidate solution. The final Requirements Document for each solution reflects the final set of ISS requirements that will be satisfied during Solution Implementation. A Residual Risk Assessment identifies any remaining ISS risks that will not be protected against by the candidate solution. These residual risks must be explicitly acknowledged and accepted by the operators of the system at the Investment Decision.   These residual risks must be considered during any preplanned product improvements or other system upgrades and enhancements.




Activity: Incorporate ISS Cost, Schedule, Performance, 
Benefits into Acquisition Program Baselines

ISS-8

Responsible
Agent

Product

Approval
Authority

Tools and Aids

Security systems engineering member of the Investment Analysis Team

Acquisition Program Baseline containing ISS performance, costs, schedule, and benefits for each candidate solution

  ISS Handbook
Description:
The Investment Analysis Team develops an Acquisition Program Baseline for each candidate solution that sets out the performance, cost, schedule, and benefit baselines to be achieved. Information System Security performance, cost schedule, and benefit factors must be included in these draft APBs.




ISS Work Activities During Solution Implementation

The following Information System Security activities are drawn from the ISS  Handbook. Initial ISS activity turns ISS requirements into a sound implementation strategy and detailed planning. Then ISS activity supports program execution as the product is designed, acquired, tested, and deployed to the field.

Activity: Develop the ISS Section of the System Specification
ISS-9

Responsible
Agent

Product

Approval
Authority

Tools and Aids

PT systems engineering specialist working with the Office of  Security & Investigations and Office of Information Systems Security

ISS requirements in the System Specification

Specification Control Board

ISS Handbook

FAA NAS System Protection Profile

Description:
The Product Team develops a System Specification, which includes Information System Security requirements, as a prelude to seeking a vendor through the source selection process. The Product Team may choose to include residual ISS requirements from Investment Analysis as options in the System Specification to allow vendors to bid system designs that meet these requirements as part of a Best Value award by the FAA. If so, satisfaction of these residual requirements must be identified as an evaluation factor in the Screening Information Request.  Requirements met by other NAS or infrastructure systems such as telecommunications and corresponding engineering and development tasks are deleted from the tailored Security Requirements list and Integrated Program Plan task list in accordance with the results of the risk analysis and decision by the DAA, ISSM, C&A Agent, PTL, and end user representative.  Often, the residual ISS requirements are stated in a lower level of detail than previously written.  The NAS System Protection Profile provides more detailed requirements that can be tailored to meet the system requirements.






Activity: Develop ISS Implementation Strategy for the ASP
ISS-10

Responsible
Agent

Product

Approval
Authority

Tools and Aids

PT systems engineer working with the Office of   Security & Investigations and Office of Information Systems Security

Strategy in the ASP for satisfying ISS requirements

PT leader, System Security Engineer and ASI personnel and facility security specialists

NIST SP 800-14 Guideline on Security Information Systems

NIST SP 800-27 Engineering Principles for ISS

Description:
The Product Team decides how best to implement Information System Security requirements, and summarizes this approach in the Acquisition Strategy Paper.



Activity: Develop ISS Tasks for the Integrated Program Plan
ISS-11

Responsible
Agent

Product

Approval
Authority

Tools and Aids

PT systems engineer working with the Office of   Security & Investigations and Office of Information Systems Security

Tasks in the IPP for executing the ISS strategy

PT leader, System security engineer, and ASI personnel and physical security specialists

ISS Handbook

NIST SP 800-14 Generally Accepted System Security Principles

Description:
The Product Team defines the tasks needed to implement Information System Security requirements, and records them in the Integrated Program Plan.



Activity: Award Prime Contract
ISS-12

Responsible
Agent

Product

Approval
Authority

Tools and Aids

PT contracting officer

Prime contract

Source selection official (typically the PT leader unless otherwise designated by the JRC)

FAA NAS System Protection Profile

Description:
A Screening Information Request is issued after completion of program planning and approval of the System Specification. The Product Team may use Information System Security compliance and quality as an evaluation factor in the award. In any case, the winning proposal must be capable of satisfying all ISS requirements in the System Specification (ISS-9).



Activity: Complete ISS Portion of System Design
ISS-13

Responsible
Agent

Product

Approval
Authority

Tools and Aids

Prime contractor
Designated System Security Engineer

ISS capability resident in system design COTS equipment defined and tailored to address ISS requirements

 

ISS Handbook

NIST SP 800-14 Generally Accepted System Security Principles

Description:
After contract award, the prime contractor implements most Information System Security activities with the Product Team overseeing contractor activity. The Product Team ensures the emerging design is fully compliant with ISS requirements in the System Specification through such activities as the Preliminary Design Review, Critical Design Review, and test and evaluation.


Activity: Complete Final System Description
ISS-14

Responsible
Agent

Product

Approval
Authority

Tools and Aids

Prime contractor

Final system description

PT leader or designated official (e.g., QRO)

 

Description:
The contractor prepares the final "as built" technical description of the system. Among other items, the technical description defines the capability of the system in response to ISS requirements in the System Specification.




Activity: Conduct Information Security Testing
ISS-15

Responsible
Agent

Product

Approval
Authority

Tools and Aids

PT test specialist System security engineer

Information Security Test Report Certification request

PT leader Certification and Accreditation Agent (AIS-300 for AIS-1)

ISS Handbook

 

 

Description:
Near the end of development, the system undergoes a battery of testing to ensure it complies correctly and completely with each Information System Security requirement in the System Specification. In addition, the system as a whole is subjected to Security Test and Evaluation (ST&E) to assess compliance with ISS specifications and its overall resistance to attack on information security. The information security test report contains the results of ST&E, as well as all test plans and procedures. The report also identifies types of testing that have not been done (e.g., due to cost or complexity), but which could nonetheless be of concern to the FAA, such as the effects of electromagnetic interference, radio frequency jamming, and communications message flooding.  The results of ST&E are provided with the rest of the evolved Security Certification & Accreditation Package (risk analyses).


Activity: Approve the Sensitive Application Certification (SAC) Report
ISS-16

Responsible
Agent

Product

Approval
Authority

Tools and Aids

Security engineer

  

Designated approving authority

ISS Handbook

Description:
 The Designated Approving Authority (DAA) certifies the new system as ISS-compliant and ready to enter operational service via signing the Authority To Operate (ATO) certificate (template in ISS Handbook) with the ISSM, AIS-1, PTL and a user representative. The ATO becomes the cover sheet for the SCAP that contains:

  • Security requirements and  high-level ISS design documents;
  • ISS assurance measures (including all ISS test procedures and results);
  • Security Plan for development, operations and maintenance; and
  • Operations and training materials pertaining to system ISS capability.
The report also thoroughly discusses residual ISS risks present in the system at the time of the In-Service Decision.




ISS Work Activities During In-Service Management 

The following Information System Security activities are drawn from the ISS Handbook. They are executed during In-Service Management when activity shifts to operating and maintaining the new capability in the field. There may also be product upgrades or pre-planned product improvements to resolve residual ISS requirements or respond to emerging threats or vulnerabilities.

Activity: Introduce Product Improvements
ISS-17

Responsible
Agent

Product

Approval
Authority

Tools and Aids

PT leader

Product upgrades

Designated In-Service decision maker

 

Description:
As new vulnerabilities emerge or as residual requirements are resolved, the Product Team develops product upgrades that can be fielded incrementally. In some cases, the upgrades can be executed though available sustainment funding and the Product Team need not return to the JRC. When additional funding is required, the Product Team prepares for a re-baselining Investment Decision to obtain approval and funding for the upgrade.