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Privacy central to new FISMA guidance

By Mary Mosquera
Published on July 17, 2008

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The Office of Management and Budget has published guidance for agencies to report how they comply with the Federal Information Security Management Act  (FISMA) for fiscal 2008. The guidance published July 16 directs agencies to take a risk-based view of information security by requiring continuous monitoring of security controls.

The guidance has additional questions related to updates of security policies and new privacy reporting requirements, Clay Johnson, OMB's deputy director for management, said in a memo that accompanied the guidance.

The FISMA reports are due Oct. 1.  OMB and Congress use these reports to evaluate agency and governmentwide security performance, so accuracy is critical, Johnson said.

“It is especially important your agency’s report clearly and accurately reflects the overall status of your program and not include conflicting views of, or unresolved differences among, the various parties contributing to the report,” Johnson said. These parties include the chief information officer, the inspector general and the senior agency official for privacy.

Agencies will need to document their progress on implementing a breach notification policy, reducing the amount of personally identifiable information and eliminating unnecessary use of Social Security numbers.

OMB is requiring agencies to implement continuous monitoring of security controls as part of the process for certification and accreditation of systems. Agencies should use the specifications for security controls and the assessment of their effectiveness available from the National Institute for Standards and Technology, the guidance said.

Among other revisions, agencies do not have to detail significant deficiencies in their annual FISMA reports to OMB, but they must have documentation about those  weaknesses available on request from OMB and oversight agencies or Congress, according to the guidance.

A significant deficiency is a weakness in an agency’s information systems security program, management control structure or within a system that would restrict the agency’s ability to carry out its mission, the guidance stated.

Agencies must document and track all security weaknesses in their Plans of Actions and Milestones. To do that, agencies may use the FISMA reporting services of a shared service provider under the Information Security Line of Business, the guidance stated. The action and milestone plans must be tied to the agency’s budget submission so the security costs for a system are linked with its security performance, the guidance also stated.


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