THE PRESIDENT’S NATIONAL SECURITY TELECOMMUNICATIONS ADVISORY COMMITTEE NS EP IMPLICATIONS OF ELECTRONIC COMMERCE JUNE 1999 President’s National Security Telecommunications Advisory Committee NS EP IMPLICATIONS OF ELECTRONIC COMMERCE TABLE OF CONTENTS EXECUTIVE SUMMARY ES-1 1 0 1 1 1 2 1 3 1 4 2 0 INTRODUCTION 1 Background 1 Purpose and Scope 1 Definitions 2 Approach 3 THE ELECTRONIC COMMERCE ENVIRONMENT 4 2 1 Commercial Use of Electronic Commerce 4 2 2 Electronic Commerce in the Federal Government 6 2 2 1 Framework for Global Electronic Commerce 6 2 2 2 Initiatives to Incorporate EC Within the Federal Government 6 3 0 ELECTRONIC COMMERCE SECURITY 11 3 1 Security Objectives 11 3 2 The EC Architecture 12 3 3 Threats to the EC Architecture 15 4 0 4 1 4 2 4 3 4 4 4 5 4 6 5 0 5 1 5 2 5 3 5 4 5 5 6 0 6 1 6 2 FACTORS AFFECTING ELECTRONIC COMMERCE RISK 18 Speed of Business 18 Rate of Technology Change 18 Commercial-Off-the-Shelf Products 19 Federal Government Information Security 20 Coordination of EC Initiatives 21 Risk Approaches 21 CONCLUSIONS 23 Anticipated Growth of NS EP Dependence on EC 23 Exposure to EC Risks and Vulnerabilities 24 Understanding NS EP Dependence on EC 24 Shared Risk 25 Lack of Unified Focus on NS EP-Specific Needs 25 RECOMMENDATIONS 27 NSTAC Recommendations to the President 27 NSTAC Direction to the IES 28 NS EP IMPLICATIONS OF ELECTRONIC COMMERCE i President’s National Security Telecommunications Advisory Committee CONTINUED APPENDIX A REPORT CONTRIBUTORS A-1 APPENDIX B REFERENCES B-1 NS EP IMPLICATIONS OF ELECTRONIC COMMERCE ii President’s National Security Telecommunications Advisory Committee EXECUTIVE SUMMARY Background The public sector is in the midst of adopting system-wide changes that will incorporate electronic commerce EC into Government operations A number of Federal Government agencies are currently investigating how EC technologies can be used to streamline their business operations For example at the President’s National Security Telecommunications Advisory Committee’s NSTAC 20th meeting the Honorable John Hamre Deputy Secretary of Defense expressed the intent of the Department of Defense DOD to move toward a paperless operation using EC technologies and state-of-the-art security tools and strategies Dr Hamre noted that moving DOD to a paperless environment is one of his top priorities The DOD initiative to incorporate EC into business operations represents the first large-scale effort toward EC by a member of the national security and emergency preparedness NS EP community The Information Infrastructure Group IIG formed the EC Subgroup to investigate the implications of incorporating EC into business operations within the NS EP community The EC Subgroup focused its efforts on the changing business and security processes and policies necessary to adopt EC and the potential implications those changes might have for NS EP operations Toward that end the IIG surveyed diverse EC literature from Government industry and academic sources In addition the IIG received a variety of briefings from Government industry and academia related to the EC environment how EC is being incorporated by the public and private sectors and EC security concerns Finally to gain greater insight into potential NS EP implications of incorporating EC into business operations the IIG interviewed public and private sector officials responsible for implementing EC policies and procedures Various departments and agencies within the Federal Government have used different forms of EC and Electronic Data Interchange EDI for a number of years However recent Federal EC initiatives mark a change from previous efforts in terms of scale and technologies used These efforts mark one of the first steps toward incorporating EC Government-wide Additionally the initiatives move away from using Government-developed technologies and standards toward using commercial products and standards where the Government has little if any control over their development As dependence on the Internet and data networks increases and as EC applications become more pervasive throughout Government and industry EC could become a critical element in supporting the NS EP posture of the Nation Conclusions This analysis focuses primarily on NS EP issues related to recent activities within the Federal Government to incorporate EC into business operations In particular the NSTAC focused on how the transition to EC could affect the departments and agencies that conduct NS EP NS EP IMPLICATIONS OF ELECTRONIC COMMERCE ES-1 President’s National Security Telecommunications Advisory Committee functions Currently EC use among such organizations has been limited to the support of nonmission critical activities However as NS EP organizations increase their reliance on EC for contracting ordering and distributing essential supplies in support of the public welfare national security posture or any other NS EP function the security of these transactions will become more critical to NS EP operations As the NS EP community transitions to EC for business operations the departments and agencies should be alert to a number of issues that could affect how EC is implemented • Initial analysis shows that the NS EP community’s current use of and dependence on EC is modest at best However a number of factors will drive the NS EP community to use EC to support its mission Consequently NS EP dependence on EC although modest at present is likely to grow steadily over the next decade • EC exposes what were once closed and paper-based business processes to the vulnerabilities of EC hardware and software and supporting information technologies It is important for the NS EP community to be aware of these vulnerabilities and make informed decisions regarding how EC technologies should be implemented to achieve an acceptable level of risk • The NS EP community may not fully understand its current or future EC dependencies It is important that NS EP departments and agencies thoroughly assess current and future dependence on EC applications and architectures the associated security implications and the effect EC will have on overall business operations • It is critical to note that in the new electronic environment created by EC the NS EP community will depend on commercial products and an information infrastructure that it neither owns nor operates Therefore the Federal Government and its partners in the private sector will share the NS EP risks involved with EC • There is a lack of a unified and specific focus on NS EP needs among organizations responsible for managing and administering oversight for EC within the Federal Government such as the Federal Electronic Commerce Program Office FECPO The Joint Electronic Commerce Program Office JECPO President’s Management Council PMC Office of Federal Procurement Policy OFPP and Federal Electronic Commerce Acquisition Team ECAT This lack of focus could lead to a lack of formal guidance policy procedures and accountability addressing NS EP issues related to the adoption of EC NS EP IMPLICATIONS OF ELECTRONIC COMMERCE ES-2 President’s National Security Telecommunications Advisory Committee Recommendations This analysis reflects the importance of encouraging a broader awareness of NS EP issues related to the introduction of EC The NSTAC has found a lack of focus on NS EP needs within these various entities Therefore there is a need to establish a focal point within the Federal Government to work with these various public and private organizations to increase their awareness of NS EP issues related to EC Our analysis has also found a need to increase the NS EP community's awareness of the potential vulnerabilities related to EC Federal departments and agencies should work with a focal point within the Federal Government to evaluate their current and future dependence on EC for NS EP mission-critical operations and develop plans and programs to address the vulnerabilities related to incorporating EC into business operations Departments and agencies need to develop a thorough understanding of their existing information architectures as well as vulnerabilities caused by the introduction of EC Once identified plans and programs can be established to protect their systems NSTAC Recommendations to the President • Recommend that the President in accordance with responsibilities and existing mechanisms established by Executive Order 12472 Assignment of National Security and Emergency Preparedness Telecommunications Functions designate a focal point for examining the NS EP issues related to widespread adoption of EC within the Government The NSTAC’s Network Group has developed recommendations proposed to help increase the NS EP community's awareness and understanding of Internet dependencies technologies and vulnerabilities and to encourage NS EP awareness among Internet organizations and initiatives In particular one recommendation states that “Recommend that the President in accordance with responsibilities and existing mechanisms established by Executive Order 12472 Assignment of National Security and Emergency Preparedness Telecommunications Functions direct the establishment of a permanent program to address NS EP issues related to the Internet ” The IIG endorses the recommendations to establish such a program and believes such a program would satisfy this recommendation • Recommend that the President direct that Federal departments and agencies in cooperation with an established Federal focal point assess the effect of EC technologies on their NS EP operations NS EP IMPLICATIONS OF ELECTRONIC COMMERCE ES-3 President’s National Security Telecommunications Advisory Committee NSTAC Direction to the IES NSTAC directs the Industry Executive Subcommittee IES to support the Government’s efforts in raising awareness of NS EP issues related to EC NS EP IMPLICATIONS OF ELECTRONIC COMMERCE ES-4 President’s National Security Telecommunications Advisory Committee 1 0 INTRODUCTION This introduction provides a background on the growth of electronic commerce EC outlines the purpose and scope of the issue analysis presents key definitions used for the analysis and summarizes the approach taken by the President’s National Security Telecommunications Advisory Committee NSTAC to determine potential national security and emergency preparedness NS EP implications related to EC 1 1 Background Advances in information technology are dramatically altering the way people communicate and conduct business In the last 5 years in particular the development of the Global Information Infrastructure GII advances in Internet technology and increased use of the World Wide Web the Web have fueled the growth of trade or EC over the Internet EC offers the potential to dramatically increase efficiency and reduce the costs of conducting business As a result many public and private organizations have adopted EC applications to increase sales cut costs and streamline logistics However as EC drives large-scale changes in business practices organizations are increasingly concerned about the security of EC applications and transactions New technologies have made critical networks more open and pervasive introducing a host of vulnerabilities Before EC can realize its full potential key partners must have confidence in the confidentiality integrity availability reliability and authenticity of the transactions conducted using EC applications and networks Although the private sector has been the driving force in the growth of EC the public sector is in the midst of adopting system-wide changes that will incorporate EC into Government operations A number of Federal Government agencies are investigating how to use EC technologies to streamline their operations For example at the NSTAC’s 20th meeting the Honorable John Hamre Deputy Secretary of Defense expressed the intent of the Department of Defense DOD to move toward a paperless operation using EC technologies and state-of-the-art security tools and strategies Dr Hamre noted that moving DOD to a paperless environment is one of his top goals 1 2 Purpose and Scope The DOD initiative to incorporate EC into business operations represents the first large-scale effort toward EC by a member of the NS EP community Since 1982 the NSTAC has addressed important issues related to the security of telecommunications and networked technologies and how those issues affect telecommunications services essential to the NS EP community NSTAC’s Information Infrastructure Group IIG formed the EC Subgroup to investigate the implications of incorporating EC into business operations within the NS EP community There are a number of issues regarding the overall security of EC and how it relates to the economic security of the Nation Several other reports have dealt with various EC issues this NS EP IMPLICATIONS OF ELECTRONIC COMMERCE 1 President’s National Security Telecommunications Advisory Committee analysis focuses explicitly on how EC will affect NS EP operations As dependence on the Internet and data networks increases and as EC applications become more pervasive throughout Government and industry EC could become a critical element in supporting the NS EP posture of the Nation Currently EC use among such organizations has been limited to the support of nonmission critical activities However as NS EP organizations increase their reliance on EC for ordering and distributing essential supplies in support of the public welfare national security posture or any other NS EP function the security of these transactions will become more critical to NS EP operations Since 1990 NSTAC has studied network security issues affecting the foundation of the U S telecommunications infrastructure namely the Public Network PN 1 The PN has remained the NSTAC’s primary focus of study because of our Nation’s increasing reliance on this infrastructure to support NS EP telecommunications This increasing reliance on the PN is driven by not only new and improved capabilities and efficiencies offered by these technologies but also the PN’s interdependence with other critical infrastructures Because of these trends in dependencies the NSTAC has expanded its focus to include key capabilities that rely on the PN Rather than addressing specific vulnerabilities affecting the PN or Internet as EC enablers this work focuses on the issues associated with the changing business and security processes and policies necessary to adopt EC 2 1 3 Definitions The NSTAC based its study on two key concepts “electronic commerce” and “NS EP telecommunications ” The definition of EC varies widely among various EC reports produced by Government industry and academia Because the subgroup was tasked to investigate how EC could affect critical NS EP operations the definition used by DOD’s Joint Electronic Commerce Program Office JECPO was found to be the most applicable For this analysis electronic commerce is defined as follows The paperless exchange of business information using Electronic Data Interchange EDI electronic mail e-mail computer bulletin boards FAX electronic funds transfer EFT and other similar technologies 3 In defining NS EP telecommunications the subgroup relied upon the National Communications System’s NCS Telecommunications Service Priority TSP Program which defines NS EP 1 The PN includes any switching system or voice data or video transmission system used to provide communications services to the public e g public switched networks public data networks private line services wireless systems and signaling networks NSIE “An Assessment of the Risk to the Security of the Public Networks ” Prepared by the U S Government and NSTAC Network Security Information Exchanges December 12 1995 2 The NSTAC is conducting separate studies to address the PN and the Internet The Government and NSTAC NSIEs are addressing the risk to the PN and the NSTAC’s Network Group is addressing NS EP dependence on the Internet 3 Joint Electronic Commerce Program Office JECPO EC EDI Handbook http www acq osd mil ec newhandbook chapter2 chapter2 htm NS EP IMPLICATIONS OF ELECTRONIC COMMERCE 2 President’s National Security Telecommunications Advisory Committee telecommunications as follows Services critical to the maintenance of a state of readiness or the response to and management of any event or crisis that causes or could cause harm to the population damage to or loss of property or degrades or threatens the NS EP posture of the United States 4 1 4 Approach To complete the task of investigating potential NS EP implications of EC the IIG EC Subgroup took the following steps • The NSTAC canvassed a broad collection of EC literature produced by Government industry and academic sources • A variety of officials from Government industry and academia briefed the NSTAC on issues related to the EC environment how EC is being incorporated by the public and private sectors and concerns regarding EC security • To gain greater insight into potential NS EP implications of incorporating EC into business operations interviews were conducted with key officials responsible for implementing Federal EC policies and procedures 4 National Communications System Office of Priority Telecommunications OPT Telecommunications Service Priority TSP Program Service Manual NCSM 3-1-1 March 1998 NS EP IMPLICATIONS OF ELECTRONIC COMMERCE 3 President’s National Security Telecommunications Advisory Committee 2 0 THE ELECTRONIC COMMERCE ENVIRONMENT Recent advances in information technology have driven what many information technology professionals call a digital revolution altering how the world communicates and conducts business In particular the growth in the use and sophistication of Internet technologies has encouraged a dramatic rise in the use of EC applications for business operations within the private sector and more recently within the public sector 2 1 Commercial Use of Electronic Commerce The use of information technology and data networks to facilitate commercial transactions is not a new practice For nearly 30 years various public and private sector organizations have used EDI to coordinate purchasing logistics sales and customer service EDI is the computer-tocomputer exchange of business information using private communications networks such as value-added networks VAN EDI never met its full potential however because the cost of installing maintaining and purchasing services on VANs was too high for small to medium-size organizations Larger organizations that could afford the investment in VANs often found that many of their business partners did not use EDI Dramatic advances in information technology IT during the last 5 years have expanded the concept of EDI More recently these advances have enabled the use of EC applications in daily business operations This change has broadened the definition of EC to include the overall paperless exchange of business information using various electronic methods The following driving factors have led EC to be used by a much wider audience • advances in telecommunications and information technologies • increased public accessibility e g the Internet and the Web and use of personal computers PC and software and • increasing use of efficiency-driven business practices e g just-in-time inventory Increased use of the Internet in particular has spurred EC growth The number of Americans using the Internet has increased from fewer than 5 million in 1993 to nearly 62 million in 1997 5 UUNET estimates that Internet traffic doubles every 100 days 6 The number of registered domain names increased from 26 000 in July 1993 to 1 3 million in 1997 In 1995 top-level commercial com domain names accounted for more than 27 000 names most representing Web sites presenting product or company information Two years later the number of 5 6 Department of Commerce The Emerging Digital Economy March 1998 p 8 Ibid p 8 NS EP IMPLICATIONS OF ELECTRONIC COMMERCE 4 President’s National Security Telecommunications Advisory Committee commercial domain names increased to 764 000 representing Web sites offering diversified services including business transactions news and information and tangible goods 7 The types of transactions that can be conducted using EC have grown over the past 3 years Business transactions conducted using EC can be generally categorized in three areas • Digital delivery of goods and services Internet and EC technologies allow for goods and services to be delivered in digital form These services include providing news and information downloading software conducting banking transactions purchasing airline tickets and buying insurance IT industry experts predict that the market for these services will increase significantly in the next few years 8 • Retail sale of tangible goods More consumers are using the Web to buy tangible goods A 1997 CommerceNet Nielsen study reported that the Internet makes it easier for consumers to research prices and offers a convenient means to buy items Nearly 10 million users in the United States and Canada have claimed that they purchased an item using the Web 9 • EC among businesses Internet commerce among businesses accounts for the largest and fastest growing percentage of EC Organizations are using EC to coordinate purchasing with suppliers logistics sales and customer service Business-to-business EC gives companies practical real-time connections with business partners reduces purchasing costs cycle times and marketing costs reduces inventories and provides more efficient customer service It is estimated that by 2002 businesses will trade more than $300 billion in goods and services using EC 10 EC offers many potential benefits for organizations interested in increased efficiency and expanded business opportunities However concerns regarding Internet security and the lack of consistent business and legal frameworks could inhibit EC’s full potential As a result organizations using EC applications are working to establish sound legal frameworks and business standards 7 Ibid p 8 Ibid p 33 9 Ibid p 35 10 Erwin Blane et al Sizing Intercompany Commerce Forrester Research July 1997 8 NS EP IMPLICATIONS OF ELECTRONIC COMMERCE 5 President’s National Security Telecommunications Advisory Committee 2 2 Electronic Commerce in the Federal Government The Federal Government has taken note of commercial trends involved with EC and is determining how it can also exploit the benefits of EC A number of initiatives show how the Federal Government is planning to incorporate EC into business operations These initiatives include the U S Working Group on Electronic Commerce the National Performance Review President’s Management Council DOD Federal Electronic Commerce Program Office FECPO and Government Paperwork Elimination Act of 1998 2 2 1 Framework for Global Electronic Commerce In December 1995 President Clinton created the U S Working Group on Electronic Commerce This signaled to Government and industry that the Internet and EC would have a strong role in the Administration’s policy agenda acknowledging the potential impact of these new technologies As a result of the Working Group’s deliberations the Administration released the Framework for Global Electronic Commerce in July 1997 The Framework established a series of principles to guide the digital economy of the future In general these principles supported private sector leadership and minimal Government intervention on EC when Government involvement is needed it should be directed at providing a predictable legal environment In addition it called for a decentralized technology-neutral approach to policy and called for international agreements to create a global EC marketplace 11 The Presidential Directive on Electronic Commerce was issued on July 1 1997 providing a strategy for the various departments and agencies implementing the Framework The Working Group is overseeing the implementation of the Framework In November 1998 it issued its first annual report Although the Framework was directed toward general commercial uses of EC it has also prompted initiatives within the Federal Government to incorporate EC as a core element of business operations 2 2 2 Initiatives to Incorporate EC Within the Federal Government Because of shrinking budgets a decreased workforce and taxpayer demand for improved performance the Federal Government has been reengineering its business operations with a focus on streamlining the procurement process The Federal Government processes 22 million transactions with the private sector each year accounting for more than $220 billion 12 An additional 10 million transactions among Federal entities adds another $450 billion to the procurement market These transactions are typically labor intensive and involve recording a significant amount of information on paper The Federal Government has realized the potential benefit that EC-related technology could bring its reengineering process As a result a series of 11 The U S Working Group on Electronic Commerce Framework for Global Electronic Commerce July 1997 The President’s Management Council Electronic Processes Initiatives Committee Electronic Commerce for Buyers and Sellers A Strategic Plan for Electronic Federal Purchasing and Payment March 1998 p 8 12 NS EP IMPLICATIONS OF ELECTRONIC COMMERCE 6 President’s National Security Telecommunications Advisory Committee initiatives are underway to incorporate EC into business operations These initiatives are being driven by the National Performance Review the President’s Management Council DOD the FECPO and the Government Paperwork Elimination Act of 1998 2 2 2 1 The National Performance Review In February 1997 the National Performance Review released its report Access America which outlined ways information technology could help the Government deliver services to the public and improve inter-governmental coordination The report outlined steps to increase citizen and business access to the most commonly requested Government services by using the Internet and other electronic technologies The report acknowledged that securing these electronic initiatives is critical when it stated “Public confidence in the security of the Government’s electronic information and information technology is essential to creating government services that are more accessible efficient and easy to use Electronic commerce e-mail and electronic benefits funds transfer sensitive information within government between the government and private industry or individuals and among governments ”13 As a result of the Access America report the Government Information Technology Services GITS Board was empowered to determine how to foster a safe and secure environment for electronic initiatives In September 1998 the GITS Board released Access with Trust a report that focuses on how the Federal Government could promote and safeguard electronic interactions with citizens industry and among departments and agencies 2 2 2 2 The President’s Management Council In March 1998 the President’s Management Council’s Electronic Processes Initiatives Committee EPIC submitted a strategic plan to Congress on using EC within the Federal Government The President’s Management Council composed of Chief Operating Officers within the Federal Government submitted the plan in response to a requirement in Section 850 of the fiscal year FY 1998 Department of Defense Authorization Act The plan states that “by the year 2001 all Federal departments and agencies will support their programs by making available customerfriendly electronic purchasing tools integrated with end-to-end commercial electronic processing of payment accounting and performance reporting information ”14 To reach this goal Federal departments and agencies will spend the next 3 years building a consistent structure for EC processes within the industry Government by • improving communications with key partners in the public and private sector • ensuring Federal departments and agencies implement commercial EC software and technologies and 13 14 National Performance Review Access America February 1997 The President’s Management Council Electronic Processes Initiatives Committee Op cit p 8 NS EP IMPLICATIONS OF ELECTRONIC COMMERCE 7 President’s National Security Telecommunications Advisory Committee • reengineering key functions of the procurement process to strengthen market research capabilities and facilitate more effective negotiations 15 2 2 2 3 Department of Defense Within the NS EP community the DOD has taken a lead in proposing the use of EC to streamline its business operations In November 1997 DOD released the Defense Reform Initiative Report DRI which outlines measures that the Department will take to change its business practices by incorporating lessons learned from corporate America A key tenet of the DRI report is to adopt EC technologies to dramatically reduce the amount of paper DOD processes and stores DOD intends to conduct most of its commercial contracting and purchasing processes using several EC tools such as EDI electronic funds transfer EFT e-mail Internet technologies computer bulletin boards and other electronic means DOD anticipates that EC applications will facilitate significant changes in DOD’s procurement and logistics processes These electronic processes will move DOD toward a modern business environment in which it can acquire and pay for goods and services more efficiently The DRI acknowledges a need to move from a “just-in-case” to a “just-in-time” approach to logistics 16 EC technology can help achieve this objective by merging warehousing and transportation functions to create just-in-time delivery results eliminating the need to store raw materials and finished components just-in-case DOD believes this approach will create a more mobile fighting force The DRI report outlines the following key goals for creating a paperless environment within DOD • By January 1 2000 all aspects of the contracting process for major weapons systems will be paper-free • By FY 2000 90 percent of DOD purchases under $2 500 will be made using the Government-wide International Merchant Purchase Authorization Card IMPAC The IMPAC card is a commercial VISA card issued to individual Government offices and organizations for official purposes • DOD will expand the use of electronic catalogs • Paper-free systems will be created for weapons support and logistics • DOD plans to discontinue volume printing of all DOD-wide regulations and instructions and make them available exclusively on the Internet or CD-ROM 17 15 Ibid p 8-11 Department of Defense Defense Reform Initiative Report November 1997 p 1 17 Ibid p 1 16 NS EP IMPLICATIONS OF ELECTRONIC COMMERCE 8 President’s National Security Telecommunications Advisory Committee To centralize management of EC initiatives within DOD JECPO was created and staffed with personnel from the Defense Information Systems Agency DISA and the Defense Logistics Agency DLA The JECPO is faced with several difficult challenges DOD has 150 accounting systems 76 procurement writing systems several different logistics systems and a major contract administration and payment system 18 Few of these systems are integrated To reach the goal of a paperless procurement environment JECPO must manage a critical examination of business practices and support processes across these various systems including how these systems can be linked electronically in a secure environment using state-of-the-art security tools Similarly the JECPO must also reach out to DOD’s contracting and trading partners and ensure that they can use state-of-the-art security tools to link to necessary systems 2 2 2 4 Federal Electronic Commerce Program Office FECPO was created in 1998 to coordinate monitor and report on the various EC initiatives within the Federal Government It acknowledges that EC is becoming a preferred way of conducting business with the Federal Government As a result the office is developing a policy framework to support EC and helping agencies develop their own EC initiatives The office is cochaired by representatives from DOD and the General Services Administration GSA The cochairs oversee three teams 1 the EC Coordination Team which works with Federal departments and agencies to coordinate and monitor implementation within the Federal Government 2 the EC Policy Team which works with Federal departments and agencies the Office of Management and Budget EPIC and other entities on creating policies to support Federal EC initiatives and 3 the Card Technology Team which works with agencies on efforts to implement government-wide implementation of card technologies As EC continues to develop within the Federal Government the FECPO is likely to play a key role in how various EC initiatives are implemented 2 2 2 5 Government Paperwork Elimination Act of 1998 On October 21 1998 Congress passed the Government Paperwork Elimination Act of 1998 a measure designed to “enhance electronic commerce by promoting the reliability and integrity of commercial transactions through establishing authentication standards for electronic communications and for other purposes ”19 The President subsequently signed the bill into law The intent of the law is to “provide a framework for reliable and secure electronic transactions with the Federal Government ”20 In passing the law Congress stated that the widespread use of 18 GAO Testimony Before the Subcommittee on Military Readiness Committee on National Security House of Representatives “Defense Management Challenges facing DOD in Implementing the Defense Reform Initiatives ” March 13 1998 p 13 19 Government Paperwork Elimination Act of 1998 P L 105-277 20 Senate Committee on Commerce Science and Transportation Government Paperwork Elimination Act Report on S 2107 Washington DC September 17 1998 NS EP IMPLICATIONS OF ELECTRONIC COMMERCE 9 President’s National Security Telecommunications Advisory Committee electronic forms would improve the speed and efficiency of Government services The law states the following • Federal agencies must make electronic versions of their reports available on-line and allow individuals and businesses to use digital signatures to file forms electronically according to guidelines established by the Director of OMB and the Secretary of Commerce • Forms submitted electronically using digital signatures would have the same legal force as written documents • The Secretary of Commerce and General Accounting Office GAO are required to periodically report on the status of the law Because the Act was only recently signed into law its effect on Federal EC initiatives is unclear however it appears to direct the Federal Government toward a possible full-scale use of EC in business operations The use of EC by Government industry and individual consumers is likely to increase during the next decade particularly in light of the rising number of public and private sector initiatives aimed at encouraging EC The security risks of EC should be considered as industry the Federal Government and the NS EP community begin to incorporate EC applications on a broader scale NS EP IMPLICATIONS OF ELECTRONIC COMMERCE 10 President’s National Security Telecommunications Advisory Committee 3 0 ELECTRONIC COMMERCE SECURITY Continuing advances in technology offer compelling reasons for more organizations to move toward EC It is likely that EC will become a significant component of essential business operations within the next decade As this trend persists it is important that organizations planning to use EC become familiar with information security objectives the nature of the EC architecture and vulnerabilities related to EC technologies 3 1 Security Objectives In most cases public and private organizations are planning to implement EC using Internet technologies which offer faster more cost-effective and efficient transactions than the more proprietary systems Although EC presents clear benefits legitimate security concerns regarding the Internet and EC applications present significant challenges that must be addressed Before users will migrate critical operations to EC technology they must have the confidence that the technology will provide the following • Data confidentiality Assurance that data is disclosed only to authorized subjects 21 • Data integrity The state that exists when computerized data is the same as that in the source documents and has not been exposed to accidental or malicious alteration or destruction 22 • Availability The property that a given resource will be usable during a given time period 23 • Reliability The probability of a given system performing its mission adequately under the expected operating conditions 24 • Authentication Providing assurance regarding the identity of a subject or object for example ensuring that a particular user is who he claims to be 25 21 Computers at Risk Safe Computing in the Information Age System Security Study Committee Computer Science and Telecommunications Board Commission on Physical Sciences Mathematics and Applications National Research Council National Academy Press Washington DC 1991 22 Glossary for Computer Systems Security Federal Information Processing Standards Publication FIPS PUB 39 U S Department of Commerce National Bureau of Standards 1976 23 Computers at Risk Safe Computing in the Information Age Op Cit 24 Glossary of Computer Security Terms DOD Directive 5200 28-STD DOD Trusted Computer System Evaluation Criteria National Computer Security Center October 1988 25 Computers at Risk Safe Computing in the Information Age Op Cit NS EP IMPLICATIONS OF ELECTRONIC COMMERCE 11 President’s National Security Telecommunications Advisory Committee • Nonrepudiation An authentication that with high assurance can be asserted to be genuine and that cannot subsequently be refuted 26 Without these assurances business transactions could be disrupted through malicious actions that intentionally block access to a computer system criminals could break into computer systems and access sensitive information or information on a computer system or in transit could be altered Vulnerabilities in information systems may allow intruders to destroy steal and modify data spread malicious code or shut down networks These vulnerabilities are exacerbated by the introduction of EC which exposes new vulnerabilities and potentially places more valued information at risk The net result is that EC will expose what were once closed and paper-based business processes to the vulnerabilities of the supporting IT technologies exploitation of such vulnerabilities may have implications for NS EP operations that rely on EC 3 2 The EC Architecture EC incorporates a wide range of business areas such as procurement logistics medical finance transportation travel and paperless contracting This section examines one area procurement in order to present an example of what tools make up an EC architecture The EC architecture is composed of processing components communications links and administrative services that collectively provide an EC solution and must all be accounted for when securing EC A vulnerability in any of these segments of the EC architecture leaves a critical opening in the system that could be used to disrupt service compromise data confidentiality and commit fraud The communications component of the EC architecture is made up of the lines routers Web servers e-mail Points of Presence POP and firewalls involved with transferring business data between various EC processing components Traditionally Value Added Networks VAN carried out the exchange of electronic data in a variety of formats However as documented previously the commercial expansion of the Internet has led to enormous interest in business-tobusiness Internet commerce The communications path for an EC data transaction now typically involves use of the Internet and Hypertext Transfer Protocol HTTP Numerous other protocols are also used to transfer information in an EC transaction such as Simple Mail Transfer Protocol SMTP File Transfer Protocol FTP and Multipurpose Internet Mail Extensions MIME The Internet was not designed for commercial purposes therefore it is currently a relatively insecure medium for conducting mission-critical business functions This situation raises concerns about using the Internet to transfer critical business information A number of steps have been taken to help ensure the security of the communications path for EC data transactions Protocols such as transmission control protocol TCP were designed to interact with the Internet Protocol IP to establish a communications path between two computers Other protocols have been designed to interact with TCP IP to further ensure the confidentiality and authenticity of data transactions Protocols such as Secure Socket Layer 26 Computers at Risk Safe Computing in the Information Age Op Cit NS EP IMPLICATIONS OF ELECTRONIC COMMERCE 12 President’s National Security Telecommunications Advisory Committee SSL Secure Electronic Transactions SET Secure Hypertext Transfer Protocol S-HTTP and Secure Multipurpose Internet Mail Extensions S MIME have been designed to use strong 56-bit to 128-bit encryption and provide a high level of security for Internet transactions With these protocols in place the EC data transaction is relatively secure leaving criminals to seek the path of least resistance Vulnerabilities in the other components of the EC architecture the EC processing components EC data stores and human roles could potentially present such a path of least resistance The processing component of the EC architecture is divided into two categories of components servers and clients which process and route business information associated with EC transactions An EC server consists of a Web server databases transaction-processing systems and interface software 27 The server provides the tools that allow an organization to conduct business with its partners and customers and keep track of transactions The EC client allows two parties in an EC transaction to communicate and is typically composed of a Web browser or a proprietary software program Table 1 lists examples of EC processing components Table 1 EC Processing Components Component Customer Access Equipment Purchasing Servers Merchant Servers Payment Servers EDI Servers Description The client that allows two parties to interface with EC servers Launch point for electronic buying Web-based link between individual users requisitioners and sellers’Web sites Electronic storefront presents the goods for sale and is a means for requisitioner to select items and place an order Process authorizations and capture transactions Used to exchange translate and archive standard business transactions such as X 12 between enterprises A key factor to consider when discussing potential vulnerabilities in EC processing components is the type of data accessed and stored in an EC transaction This data could provide valuable information malicious actors could use for their own gains Examples of data stored in an EC transaction include the following 27 Ghoush Anup “Securing the Web Server Windows NT versus Unix ” This paper was submitted to the National Computer Security Association conference Electronic Commerce Security held in Washington DC on August 4 1997 NS EP IMPLICATIONS OF ELECTRONIC COMMERCE 13 President’s National Security Telecommunications Advisory Committee • User Profiles Maintained by purchasing organizations Includes information about the users such as user name user account purchasing authorizations shipping address electronic mail address and pre-approved transaction limits May also be extended to track information on user preferences and buying habits • Trading Partner Databases Captures the contractual arrangements between trading partners Maintained by purchasing and selling organizations the data contained is the result of trading partner negotiation and registration • Seller’s Catalogs Also known as electronic storefronts the catalogs maintain and display contractually defined sets of products and services available to authorized users • Orders The information workflow steps approvals account and tax status information necessary to complete an order • EDI Transactions Ongoing and archived business transactions between trading partners • Additional Data Stores EC functions must typically interface with legacy accounting personnel and inventory systems It is critical to note that organizations adopting EC must realize that potential vulnerabilities in EC processing components e g flawed Web servers and browsers misconfigured operating systems and inadequate access controls to databases threaten the robustness of the EC architecture and could provide unauthorized access to sensitive stored information The human factor is another critical element affecting the security of the server and client A typical EC transaction involves a series of administrative services The following roles must be filled in order to process and route an EC transaction • Requisitioner The requisitioner affiliated with the purchasing organization places the orders for the products and or services • Purchasing Organization The purchasing organization manages the processes and information systems that support purchasing and the communications links to suppliers The purchasing organization maintains an EDI server for transaction management e g receiving and returning orders translation routing and archiving NS EP IMPLICATIONS OF ELECTRONIC COMMERCE 14 President’s National Security Telecommunications Advisory Committee • Selling Organization Each selling organization publishes electronic catalogs listing its goods and or services and processes orders Additionally the selling organization maintains links with the appropriate payment authorities • Payment Authority The payment authority provides authorization for the payment vehicle presented by the requisitioner makes payments to the selling organization and invoices or debits the buying organization Because an EC transaction involves a number of different human interactions the potential for human error is a critical factor Often employees have not been trained in software security and either through error or disregard for organizational data security practices they can make the architecture more vulnerable to attack 3 3 Threats to the EC Architecture The threat to an EC architecture mirrors the traditional threat to information systems Motives for attacking an EC architecture are as varied as the types of intruders conducting the attacks Architectures may be attacked for national interests financial gain industrial espionage power revenge prestige ideology and simple curiosity 28 Examples of perceived threats to the NS EP community’s potential use of EC include • Errors Errors occur when a system user either through a lack of training or failure to follow established security procedures performs an action that exacerbates or exploits a vulnerability in the system 29 This action could lead directly to loss of information on a critical system or expose a system to a vulnerability • Malicious Insiders The insider is a significant threat to information system security Unauthorized access by insiders accounts for nearly 80 percent of information system breaches 30 The multi-faceted threat includes disgruntled employees paid informants compromised or coerced employees former employees and contractors The 1998 NSIE White Paper “The Insider Threat to Information Systems ” noted that insiders have the opportunity capability and motivation to attack an information system 31 28 NSIE “An Assessment of the Risk to the Security of the Public Networks ” Prepared by the U S Government and NSTAC Network Security Information Exchanges December 12 1995 p 11 29 Office of the Under Secretary of Defense for Acquisition and Technology “Report of the Defense Science Board Task Force on Information Warfare-Defense IW-D ” November 1996 p 30 http www jya com iwdmain htm 30 Nichols Randall K “Commercial Information Security Tiger Teams and Encryption ” This paper was submitted to the National Computer Security Association conference Electronic Commerce Security held in Washington DC August 4 1997 31 OMNCS “The Insider Threat to Information Systems A Framework for Understanding and Managing the Insider Threat in Today’s Business Environment ” prepared by the U S Government and NSTAC National Security Information Exchanges April 1998 p 4 NS EP IMPLICATIONS OF ELECTRONIC COMMERCE 15 President’s National Security Telecommunications Advisory Committee • Foreign Governments To support national interests many countries have established relationships with businesses and Government entities to develop a capability to collect economic scientific technological and military intelligence The NSIE assessment of the risk to the security of the Public Network pointed out that it is difficult to assess the full magnitude of the threat posed by foreign Government sponsored activities because many companies do not fully document or share their intrusion experiences 32 • Industrial Spies Industrial espionage focuses on obtaining research and development strategies manufacturing and marketing plans and customer lists 33 As those industries comprising the critical infrastructures become less regulated e g telecommunications and electric utilities they are becoming increasingly competitive which could lead to an increase in industrial espionage • Criminals A variety of criminal elements are beginning to attack information systems and networks for immediate financial gain and valuable inside information about business operations or even law enforcement activities As more organizations use information systems for critical information and financial transactions it is expected that all levels of criminals will continue to target valuable information systems 34 • Hackers The hacker threat involves individuals or groups who have the technical knowledge and an understanding of the processes needed to penetrate information systems The motivation for hackers ranges from curiosity to financial gain Although the threat to EC is diverse it is important to note that the same advances in information technologies that have spurred the growth of EC have also enabled intruders to attack critical systems Rapid advances in technology have made computer applications needed to launch an electronic intrusion more affordable user-friendly and readily available 35 In addition the Internet allows hackers to rapidly disseminate information on vulnerabilities and attack methods leading to repeated attacks after a vulnerability is found Considering the vulnerabilities involved with EC and the potential that those vulnerabilities could be exploited it is critical for organizations to craft comprehensive plans to protect their critical systems This plan should involve both administrative and technical tools Examples of administrative tools include developing a detailed security policy and educating employees on that policy establishing a central management focal point to oversee security backing up critical data and making contingency plans should information systems fail Technical protection measures 32 NSIE “An Assessment of the Risk to the Security of the Public Networks ” Op Cit p 10 Nelson Jack “U S Firms’’97 Losses to Spies Put at $300 Billion ” Los Angeles Times January 12 1998 34 Office of the Under Secretary of Defense for Acquisition and Technology Op Cit p 30 35 OMNCS “Electronic Intrusion Threat to National Security and Emergency Preparedness Telecommunications An Awareness Document ” March 1999 33 NS EP IMPLICATIONS OF ELECTRONIC COMMERCE 16 President’s National Security Telecommunications Advisory Committee should begin with access controls such as password protection properly configured firewalls or other access devices such as smart cards that protect systems from unauthorized access In addition encryption plays a major role in providing technical protection measures Organizations should consider tools such as SSL or SET each of which uses encryption to ensure data integrity and data confidentiality For further protection organizations should use digital signatures which use encryption techniques to ensure data integrity and nonrepudiation by allowing recipients of a message to ensure that a sender is authentic Combining message encryption in the form of SSL with digital signatures can strengthen the security of an EC environment NS EP IMPLICATIONS OF ELECTRONIC COMMERCE 17 President’s National Security Telecommunications Advisory Committee 4 0 FACTORS AFFECTING ELECTRONIC COMMERCE RISK As the Federal Government and the NS EP community migrate to commercial standards and practices through the use of EC it is important to understand the implications of these emerging commercial trends and how they affect EC risk This section explores technological and commercial trends that may increase the vulnerability of EC systems Over the past decade a number of organizations within the commercial sector have integrated EC into their commercial standards and practices reflecting a number of characteristics of the introduction of new information technologies These characteristics include a change in the speed of business an increase in the rate of technology the use of commercial-off-the-shelf products COTS existing concerns over information security within the Federal Government and finally issues related to the differing views on risk between the public and private sectors 4 1 Speed of Business The commercial world is a highly competitive arena where bringing the best product or service to market quickly is essential EC benefits organizations by increasing the efficiency of their business operations Commercial businesses have used advances in EC technology to move from a “justin-case” to a “just-in-time” approach to logistics Just-in-case logistics involves storing large quantities of warehoused inventory just in case they are needed With advances in EC technologies organizations can communicate with their suppliers at a much faster rate and suppliers can fulfill their requests “just-in-time ” As a result a new paradigm has emerged Justin-time is an inventory management process designed to reduce the warehousing of large quantities of components that may occupy a space for a brief period of time before they are needed The just-in-time approach takes advantage of the speed and efficiency of EC and merges the warehousing and transportation functions to place components at the manufacturing site or the retail store coincident with the anticipated need for the items eliminating the need to stockpile components Organizations can manage their inventories more effectively reduce operating costs improve customer service and react quickly to changes in customer demand Recognizing how just-in-time logistics has revolutionized the commercial sector the DOD has taken steps to incorporate EC and establish a new logistics mindset within the U S military 36 4 2 Rate of Technology Change We are living in a world of incredible technology change In 1983 when the personal computer was becoming more widely adopted the life-cycle of technology was about 5 years Today rapid advances in information technology have dramatically reduced the life cycle to 6 to 8 months This has caused problems in planning for the introduction of new technologies and practices Historically the strategic planning time frame has been 3 to 5 years the operational planning time frame has been 1 to 3 years Rapid advances in technology have compressed these planning 36 Department of Defense Defense Reform Initiative Report November 1997 NS EP IMPLICATIONS OF ELECTRONIC COMMERCE 18 President’s National Security Telecommunications Advisory Committee cycles reducing the strategic planning time frame to 1 year and operational planning time frame to a matter of a few months Organizations now run the risk of using technologies before they have developed the methodologies and practices needed to support those technologies Electronic commerce encompasses a wide variety of new and emerging technologies Incorporating EC involves introducing a whole new set of technologies that reengineer business operations To implement EC successfully organizations must be sufficiently flexible to develop effective methodologies and practices to support new EC technologies within the short time frame demanded by the rapid rate of technological change and a compressed planning cycle 4 3 Commercial-Off-the-Shelf Products Organizations incorporating EC are doing so largely by using COTS software and hardware products These organizations are turning to COTS products primarily because they are less expensive than custom-built components Examples of COTS products include Web servers browsers operating systems and database systems Several general security issues exist in the use of COTS products From an end-user consumer point-of-view COTS products tend to be generic solutions for non-specific problems Consumers have little or no ability to affect the design development or testing of any COTS products Although such products promote consistent business practices which is a distinct advantage they do not accommodate unique business processes Continuing upgrades are available for major software products but these are designed to address the needs of the widest population and are not tailored to the unique needs of a single business Organizations using COTS products must be ready and able to reengineer their business operations to accommodate the software In addition the COTS market is largely influenced by availability Generally the first product to market has the greatest opportunity to gain market share and establish a standard for that product Because fixes are often bundled with new releases and upgrades the problem of applying the needed solution is further complicated by the uncertainties of the robustness and pre-testing of the new release and its effect on system performance 37 As a result the industry is pressed to release a product in a relatively short time and sometimes is forced to reduce the time spent in testing the product 38 This leads to flaws in product design that could introduce vulnerabilities to a system As COTS components with design flaws are replicated throughout the market the vulnerabilities are also replicated throughout a wide section of end users Although design flaws are generally discovered and fixes distributed organizations may not be aware of them and are generally unable and sometimes unwilling to implement needed fixes This problem degrades system integrity leaving it vulnerable to technological failure or to attack because malicious actors are often aware of product design flaws and exploit them Therefore organizations using COTS products to incorporate EC need to be alert to potential design flaws and stand ready to 37 Computer Science and Telecommunications Board National Research Council Trust in Cyberspace Washington DC National Research Council Press January 1999 Chapter 3 pp 102-103 38 Ibid p 101 NS EP IMPLICATIONS OF ELECTRONIC COMMERCE 19 President’s National Security Telecommunications Advisory Committee implement necessary fixes In particular the NS EP community must stand alert as it shifts from using products built according to its own standards toward using COTS products over which it has little if any control 4 4 Federal Government Information Security In addition to the vulnerabilities affecting the use of EC in the commercial sector several trends are operating within the Federal Government that could significantly affect Federal departments and agencies as they adopt EC The Federal Government’s reliance on information systems has been growing over the past decade Many of the essential functions performed by the Government such as procurement logistics and benefit disbursement already depend on electronic data and automated information systems More services that support national defense and law enforcement are also using sophisticated information systems because of their costeffectiveness speed and efficiency However there are questions concerning the security of those information systems In a report issued September 1998 the GAO summarized audit reports issued by the agency from March 1996 through August 1998 that had found substantial weaknesses in the security of information networks in 24 agencies The September 1998 GAO report said “Significant information security weakness were identified in each of the 24 agencies covered by our analysis agencies that in fiscal year 1997 accounted for 99 percent of reported Federal outlays ”39 Poor control over the access to sensitive data and systems was the mostly widely reported weakness discovered by GAO audits Weaknesses in access controls can be exploited to disrupt critical operations at these agencies and could place sensitive data and assets at risk In addition to the access control issue the GAO report also found that poor security planning and management was a problem in 17 agencies Of the agencies noted in the report most have begun to develop policies and procedures to address their information security weaknesses but questions exist about the effectiveness of these policies and whether these policies are based on an adequate assessment of risk Many Federal departments and agencies still need to establish a framework within their organization for identifying and assessing risks to their information systems These information security concerns with Federal departments and agencies raise significant questions as the Government moves to the widespread adoption of EC The widespread adoption of EC would use many of the same information systems determined by the GAO as having significant security weaknesses This move could potentially place even more sensitive information and assets at risk 39 GAO Information Security Serious Weaknesses Place Critical Federal Operations and Assets at Risk Washington DC September 1998 p 23 NS EP IMPLICATIONS OF ELECTRONIC COMMERCE 20 President’s National Security Telecommunications Advisory Committee 4 5 Coordination of EC Initiatives Various Federal departments and agencies over the past few years have recognized the benefits that EC would bring to their business operations Government managers have begun to implement EC within their own organizations on an ad hoc basis often using policies and procedures that differ from those of other departments and agencies This practice has created interoperability problems within the Federal Government and between the Federal Government and its partners in the private sector This situation has led to an effort to standardize the move to EC by creating within the Federal Government a “single face to industry ” Initiatives by the President’s Management Council DOD GSA and FECPO have sought to create policies and procedures to standardize Federal EC programs However differences in agency missions and needs have shown that standardization is difficult and coordination of EC efforts at this time is elusive Standardizing EC operations among departments and agencies with disparate missions is difficult in the absence of a strong entity within the Government to coordinate EC efforts Coordination is key in developing a standard baseline of EC security throughout the Government Accordingly the overall security associated with EC may be compromised by stakeholders with disparate security concerns and approaches 4 6 Risk Approaches The commercial sector makes business decisions based on how the decision will affect the bottom line profitability shareholders market share etc Decisions are based upon a business case with an understanding that some degree of risk must be accepted Many businesses have decided that the overall benefit of EC outweighs the potential risks The commercial sector generally has a higher tolerance for risk than the Government has traditionally had Although the commercial sector acknowledges threats and vulnerabilities cost-effectiveness is the driving factor in deciding how to mitigate vulnerabilities Even with the vulnerabilities that are introduced given the nature and speed of business change and the accelerating rate of technology change it is clear that EC is becoming a critical component of commercial business operations Many of the vulnerabilities and trends affecting EC and discussed in this analysis are likely to persist for the next decade if not longer Historically the Federal Government has tended to have a lower tolerance of risk almost practicing risk avoidance The objective had been a continuing practice of attempting to eliminate all vulnerabilities and develop protection measures against all postulated threats However with the deployment of new technologies the Government has acknowledged that it must move away from a risk avoidance mentality 40 This changing philosophy needs time to permeate throughout the culture of the Federal Government However contention among various Government entities as to what constitutes “acceptable risk” may stall this process The benefits of incorporating EC 40 The Joint Security Commission Redefining Security A Report to the Secretary of Defense and the Director of the Central Intelligence Agency February 28 1994 Washington DC NS EP IMPLICATIONS OF ELECTRONIC COMMERCE 21 President’s National Security Telecommunications Advisory Committee may be too great for the Federal Government to reject what EC offers Consequently the Government should not avoid EC because of its potential risks rather it should determine the acceptable level of risk and implement measures that will achieve that objective NS EP IMPLICATIONS OF ELECTRONIC COMMERCE 22 President’s National Security Telecommunications Advisory Committee 5 0 CONCLUSIONS The focus of this report is to identify NS EP issues related to recent activities within the Federal Government to incorporate EC into business operations The NSTAC focused on how the transition to EC could affect the departments and agencies that conduct NS EP functions The analysis assessed how the use of EC would affect 1 mission-critical operations necessary to respond to an NS EP event or crisis and 2 general operational activities that if disrupted might impair the ability of Federal departments and agencies to fulfill their NS EP responsibilities Various departments and agencies within the Federal Government have used different forms of EC and EDI for many years However recent Federal EC initiatives have marked a change from previous efforts based on scale and technologies used These efforts mark one of the first forays into incorporating EC on a government-wide scale As the NS EP community transitions to EC for business operations departments and agencies should be alert to a number of issues that could affect how EC is implemented 5 1 Anticipated Growth of NS EP Dependence on EC Initial analysis shows that the NS EP community’s current use of and dependence on EC is modest at best The recent move to incorporate EC using commercial standards is still very early in the process marked by nearly 30 EC pilot programs within various departments and agencies At this stage determining tangible results from either the success or failure of these programs may be premature However a number of factors drive the NS EP community to incorporate EC into its business operations As noted earlier many private organizations have been using EC applications for several years and have experienced tangible improvement to their overall business operations Industry has demonstrated that electronic capabilities such as Internet-based EC offer a cost-effective and efficient means to conduct business The Federal Government has taken note of this trend and is reengineering its processes to exploit the benefits of EC The NS EP community has been hesitant to move to EC because of concerns over its security Private industry’s use of EC and its desire to conduct business with the Government electronically will continue to affect EC efforts within the Government Based on the sheer number of initiatives and champions of EC within the Government it appears that the use of EC will increase over the next decade The NS EP community may find its hesitance to use EC to support its mission overcome by events Consequently NS EP dependence upon EC while modest at this time is likely to grow steadily over the next decade NS EP IMPLICATIONS OF ELECTRONIC COMMERCE 23 President’s National Security Telecommunications Advisory Committee 5 2 Exposure to EC Risks and Vulnerabilities EC exposes what were once closed and paper-based business processes to the vulnerabilities of EC processing components and supporting information technologies EC relies on information systems and an underlying communications medium e g the Internet and PN Vulnerabilities can exist within any of these segments Incorporating EC into an organization’s business operations introduces additional vulnerabilities that have the potential to affect the robustness of information systems and could allow unauthorized access to sensitive stored information These vulnerabilities could be caused by design flaws in EC processing components errors in implementing EC components and human error Because the Federal Government’s use of EC is relatively new it is difficult to determine how vulnerabilities in EC technologies might affect Government operations The move toward EC could potentially place sensitive information and assets at greater risk The uncertainty related to EC vulnerabilities requires a new approach to risk management This new approach must address new vulnerabilities threats and consequences and reconsider what constitutes an acceptable level of risk It is important for the NS EP community to be aware of the vulnerabilities and make informed decisions regarding how EC technologies should be implemented to achieve an acceptable level of risk 5 3 Understanding NS EP Dependence on EC As the NS EP community considers and adopts additional processes that require EC it becomes increasingly important to assess the extent of this dependence and to determine potential consequences At this stage many departments and agencies in the NS EP community may not fully understand their current or future EC dependencies and consequently could fail to take adequate measures to protect their infrastructures This new electronic environment is marked by dramatic changes caused by the dependence on technology a new paradigm of just-in-time logistics new procurement systems and a change in relationships among manufacturers suppliers vendors and customers The NS EP community will be required to develop a policy framework and reconfigure its systems to adapt to the dynamic electronic environment This effort will require the NS EP community to thoroughly assess its current and future dependence on EC applications and architectures the security requirements and capabilities of its missioncritical networks and the effect EC will have on its overall business operations Once EC measures are adopted the burden is on each department or agency to continually stay aware of the operations affected by EC and develop methodologies and practices to mitigate vulnerabilities NS EP IMPLICATIONS OF ELECTRONIC COMMERCE 24 President’s National Security Telecommunications Advisory Committee 5 4 Shared Risk The Federal Government will face a new challenge as it integrates EC into its business operations and the boundaries of its new EC systems extend into the information infrastructures of its commercial business partners An organization’s security solution can be viewed as a chain that is only as strong as its weakest link As the Government adds trusted users systems and or networks through outsourcing business partnering etc security in the emerging electronic environment very much depends on the shared burden of security by any interconnected component It is critical to note that in the new electronic environment created by EC the NS EP community will depend on commercial products and an information infrastructure that it does not own and operate Recent EC initiatives move away from using Government developed technologies and standards toward using commercial products and standards where the Government has little if any control over their development Therefore the Federal Government and its partners in the private sector must share the NS EP risks involved with EC The public and private sector together will need to ensure that they build robust and reliable networks and secure their information 5 5 Lack of Unified Focus on NS EP-Specific Needs A number of organizations provide management and administration oversight for implementing EC within the Federal Government including the JECPO FECPO President’s Management Council PMC Office of Federal Procurement Policy OFPP and Federal Electronic Commerce Acquisition Team ECAT The lack of a unified and specific focus on NS EP-related EC needs among these organizations could lead to a lack of formal guidance policy procedures and accountability related to NS EP needs Coordination is key in developing a standard baseline of EC security throughout the Government that would allow the NS EP community to meet its critical functions in the new emerging electronic environment It is essential that public and private organizations assisting with administration implementation and management of EC be made aware of the NS EP community’s needs The NS EP community should increase NS EP awareness among the various EC management organizations and continue to proceed cautiously on use of and dependence on EC Concurrent with this effort by the IIG the NSTAC’s Network Group NG has been conducting a broad study addressing the overall NS EP dependence upon the Internet The report examines not only the extent to which NS EP operations will directly and indirectly depend on the Internet over the next 3 years but also how NS EP operations might be affected by Internet failures The NG has developed recommendations proposed to help increase the NS EP community's awareness and understanding of Internet dependencies technologies and vulnerabilities and to encourage NS EP awareness among Internet organizations and initiatives In particular one recommendation states that “in accordance with responsibilities and existing mechanisms NS EP IMPLICATIONS OF ELECTRONIC COMMERCE 25 President’s National Security Telecommunications Advisory Committee established by Executive Order 12472 Assignment of National Security and Emergency Preparedness Telecommunications Functions the President should direct the establishment of a permanent program to address NS EP issues related to the Internet ” This program would work with the NS EP community to broaden understanding of evolving direct and indirect Internet dependencies and work with key Internet organizations and standards bodies to increase awareness of NS EP requirements Our analysis of NS EP issues related specifically to EC has found that a major factor driving the increased use of the Internet by the Federal Government is the broad push to incorporate EC into business operations The IIG believes that a permanent program established to address NS EP issues related to the Internet would address NS EP issues related to EC The focus of this program should include issues specifically related to the use of EC e g vulnerabilities in EC processing components securing EC architectures and the need for contingency planning and raise awareness within the public and private sectors of issues resulting from the emerging NS EP dependency on EC NS EP IMPLICATIONS OF ELECTRONIC COMMERCE 26 President’s National Security Telecommunications Advisory Committee 6 0 RECOMMENDATIONS This analysis reflects the importance of encouraging a broader awareness of NS EP issues related to the introduction of EC This report identifies a number of organizations e g FECPO JECPO President’s Management Council Office of Federal Procurement Policy and Federal Electronic Commerce Acquisition Team that provide management and administration oversight for implementing EC initiatives within the Federal Government In addition a number of entities in the private sector e g service providers hardware and software vendors perform critical roles by designing manufacturing implementing operating and maintaining the infrastructures that support EC The NSTAC has found a lack of focus on NS EP needs within these various entities Therefore there is a need to establish a focal point within the Federal Government to work with these various public and private organizations to increase their awareness of NS EP issues related to EC Our analysis has also found a need to increase the NS EP community's awareness of the potential vulnerabilities related to EC Federal departments and agencies should work with a focal point within the Federal Government to evaluate their current and future dependence on EC for NS EP mission-critical operations and develop plans and programs to address the vulnerabilities related to incorporating EC into business operations Departments and agencies need to develop a thorough understanding of their existing information architectures as well as vulnerabilities caused by the introduction of EC Once identified plans and programs can be established to protect their systems 6 1 NSTAC Recommendations to the President • Recommend that the President in accordance with responsibilities and existing mechanisms established by Executive Order 12472 Assignment of National Security and Emergency Preparedness Telecommunications Functions designate a focal point for examining the NS EP issues related to widespread adoption of EC within the Government As noted in Section 5 5 the NSTAC’s Network Group has developed recommendations proposed to help increase the NS EP community's awareness and understanding of Internet dependencies technologies and vulnerabilities and to encourage NS EP awareness among Internet organizations and initiatives In particular one recommendation states that “Recommend that the President in accordance with responsibilities and existing mechanisms established by Executive Order 12472 Assignment of National Security and Emergency Preparedness Telecommunications Functions direct the establishment of a permanent program to address NS EP issues related to the Internet ” The IIG endorses the recommendation to establish such a program and believes such a program would satisfy this recommendation NS EP IMPLICATIONS OF ELECTRONIC COMMERCE 27 President’s National Security Telecommunications Advisory Committee • Recommend that the President direct that Federal departments and agencies in cooperation with an established Federal focal point assess the effect of EC technologies on their NS EP operations 6 2 NSTAC Direction to the IES NSTAC directs the Industry Executive Subcommittee IES to use existing NSTAC mechanisms to support the Government’s efforts in raising awareness of NS EP issues related to EC NS EP IMPLICATIONS OF ELECTRONIC COMMERCE 28 President’s National Security Telecommunications Advisory Committee APPENDIX A REPORT CONTRIBUTORS NS EP IMPLICATIONS OF ELECTRONIC COMMERCE APPENDIX A President’s National Security Telecommunications Advisory Committee PARTICIPANTS Unysis MCI WorldCom CSC GTE ITT NTA SAIC TRW Unisys U S WEST Dr Dan Wiener IIG Chair Mr Mike McPadden Task Chair Mr Guy Copeland Mr Lowell Thomas Ms Ernie Gormsen Mr Joe Gancie Mr Dave Kelly Mr Bob Burns Ms Rosemary Dew Mr Bob Lentz Mr Fred Tompkins Mr Jon Lofstedt OTHER CONTRIBUTORS Boeing DOC DOD EOP FECPO GSA JECPO RST UMD Mr Graeber Jordan Mr Roger Baker Mr Bill Belote Mr Paul London Mr Michael Mestrovich Mr Lin Wells Mr Ira Magaziner Mr Paul Grant Mr Thomas Burke Mr Tom Sellers Ms Diana Marshall Mr Anup Ghoush Mr Don Riley NS EP IMPLICATIONS OF ELECTRONIC COMMERCE A-1 President’s National Security Telecommunications Advisory Committee APPENDIX B REFERENCES NS EP IMPLICATIONS OF ELECTRONIC COMMERCE APPENDIX B President’s National Security Telecommunications Advisory Committee Magazine Newspaper Press Release Articles Nelson Jack “U S Firms’’97 Losses to Spies Put at $300 Billion ” Los Angeles Times January 12 1998 National Security Telecommunications Advisory Committee NSTAC Information Infrastructure Group IIG Briefings Administration Efforts to Facilitate Global Electronic Commerce Ira Magaziner Senior Policy Advisor to the President April 1 1998 Department of Defense Policies Concerning Electronic Commerce Dr Lin Wells Office of Undersecretary of Defense for Policy April 1 1998 EC Security Weak Links Best Defenses Anup Ghoush Reliable Software Technologies June 17 1998 Federal Electronic Commerce Program Paul Grant Federal EC Program Office April 22 1998 Global Business Interfaces Integrating EC Business Applications in Global Defense Dr Michael Mestrovich Office of Undersecretary of Defense for Acquisition and Technology March 11 1998 Joint Electronic Commerce Program Office Diana Marshall July 17 1998 Overview of DOC Internet and EC Programs Roger Baker and Paul London DOC October 8 1998 Overview of GSA Internet and EC Programs Thomas Burke GSA October 8 1998 The Payoff of the Boeing Web Graeber Jordan Boeing November 6 1998 United Nations EC Project Don Riley University of Maryland College Park October 8 1998 NS EP IMPLICATIONS OF ELECTRONIC COMMERCE B-1 President’s National Security Telecommunications Advisory Committee Office of the Manager National Communications System OMNCS – Sponsored Documents An Assessment of the Risk to the Security of the Public Networks prepared by the U S Government and NSTAC Network Security Information Exchanges December 12 1995 Electronic Intrusion Threat to National Security and Emergency Preparedness Telecommunications An Awareness Document Office of the Manager National Communications System March 1999 The Insider Threat to Information Systems A Framework for Understanding and Managing the Insider Threat in Today’s Business Environment prepared by the U S Government and NSTAC National Security Information Exchanges April 1998 Office of Priority Telecommunications OPT Telecommunications Service Priority TSP Program Service Manual NCSM 3-1-1 March 1998 Other Computer Science and Telecommunications Board National Research Council Trust in Cyberspace Washington DC National Research Council Press January 1999 Department of Commerce The Emerging Digital Economy March 1998 Department of Defense Defense Reform Initiative Report November 1997 Erwin Blane et al Sizing Intercompany Commerce Forrester Research July 1997 General Accounting Office Information Security Serious Weaknesses Place Critical Federal Operations and Assets at Risk Washington DC September 1998 General Accounting Office Testimony Before the Subcommittee on Military Readiness Committee on National Security House of Representatives “Defense Management Challenges Facing DOD in Implementing the Defense Reform Initiatives ” March 13 1998 Ghoush Anup “Securing the Web Server Windows NT versus Unix ” Paper submitted to the National Computer Security Association conference Electronic Commerce Security held in Washington DC on August 4 1997 NS EP IMPLICATIONS OF ELECTRONIC COMMERCE B-2 President’s National Security Telecommunications Advisory Committee Glossary for Computer Systems Security Federal Information Processing Standards Publication FIPS PUB 39 U S Department of Commerce National Bureau of Standards 1976 Glossary of Computer Security Terms DOD Directive 5200 28-STD DOD Trusted Computer System Evaluation Criteria National Computer Security Center October 1988 Government Paperwork Elimination Act of 1998 P L 105-277 Joint Electronic Commerce Program Office JECPO EC EDI Handbook http www acq osd mil ec newhandbook chapter2 chapter2 htm The Joint Security Commission Redefining Security A Report to the Secretary of Defense and the Director of the Central Intelligence Agency February 28 1994 Washington DC National Performance Review Access America February 1997 Nichols Randall K “Commercial Information Security Tiger Teams and Encryption ” paper submitted to the National Computer Security Association conference Electronic Commerce Security held in Washington DC August 4 1997 Office of the Under Secretary of Defense for Acquisition and Technology Report of the Defense Science Board Task Force on Information Warfare-Defense IW-D November 1996 The President’s Management Council Electronic Processes Initiatives Committee Electronic Commerce for Buyers and Sellers A Strategic Plan for Electronic Federal Purchasing and Payment March 1998 Senate Committee on Commerce Science and Transportation Government Paperwork Elimination Act Report on S 2107 September 17 1998 System Security Study Committee Computer Science and Telecommunications Board Commission on Physical Sciences Mathematics and Applications National Research Council Computers at Risk Safe Computing in the Information Age National Academy Press Washington DC 1991 The U S Working Group on Electronic Commerce Framework for Global Electronic Commerce July 1997 NS EP IMPLICATIONS OF ELECTRONIC COMMERCE B-3
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