**CASE STUDY IS ATTACHED** >>PLEASE DO NOT BID UNLESS YOU UNDERSTAND IT SECURITY — IN PARTICULAR NIST PUBLICATIONS — AND CAN REVIEW, THEN TIE IN CASE STUDY INFORMATION<
definitions and terminology.
3.
Use a professional format for your policy
documents and briefing package. Your
policy documents should be consistently formatted and easy to read.
4.
Common phrases do not require citations. If
there is doubt as to whether or not information requires attribution, provide a
footnote with publication information or use APA format citations and
references.
5.
You are expected to write grammatically correct
English in every assignment that you submit for grading. Do not turn in any
work without (a) using spell check, (b) using grammar check, (c) verifying that
your punctuation is correct and (d) reviewing your work for correct word usage
and correctly structured sentences and paragraphs.
Submit For Grading
Submit briefing package in MS Word format (.docx or
.doc file) for grading using your assignment folder. (Attach the file.)
Grading Rubric:
Executive Summary for the Policy Briefing Package 10
points
The Executive Summary provided an excellent summary of the
policy package’s purpose and contents. Information about the case study company
was well integrated into the summary. Each policy was individually introduced
and clearly explained. The material was well organized and easy to read.
Policy Introduction 10 points
The policy contained an excellent introduction which
addressed five or more specific characteristics of the company’s business,
legal & regulatory, and/or enterprise IT environments and addressed the
reasons why employees must comply with this policy. Compliance requirements are
addressed and contact information is provided for questions about the policy.
Policy Content 10
points
The issue specific policy provided excellent (clear and
concise) coverage of the following:
·
policy issue (do required policies exist and
have they been properly vetted & approved)
·
policy solution (auditing all IT security
policies to determine compliance with security controls)
·
applicability (to what and to whom the policy
applies)
·
compliance requirements
·
point of contact (for more information)
The policy was easy to understand and thoroughly covered the
required content.
Security Awareness Audit Plan: Audit Background 10
points
The Security Awareness audit plan contained an excellent
background section which identified and discussed 5 or more risks which drive
the requirements and objectives for this audit. IT security controls for
security awareness (AT family of controls from NIST SP 800-53) and related
compliance requirements were identified and discussed. Contact information was
provided for the audit manager. Information from the case study was well
integrated into the background material.
Security Awareness Audit Plan: Audit Objectives 5 points
A clear and concise set of audit objectives were presented.
These objectives addressed (and named) each security control in the Awareness
& Training (AT) family (as listed in NIST SP 800-53).
Security Awareness Audit Plan: Audit Approach15 points
The Audit Approach clearly and concisely identified and
described the major elements in the data collection strategy (what data will be
collected, how it will be collected, what will be measured). The data
collection strategy was supported by a checklist (for a document review) or
list of questions (for a survey). The relationship between the audit approach
and the measurement of the effectiveness of the security controls
implementation was explained.
IT Security Policies Audit Plan: Audit Background 10
points
The IT Security Policies audit plan contained an excellent
background section which identified and discussed 5 or more risks which drive
the requirements and objectives for this audit.
The 18 IT security policies & procedures security
controls (e.g. AC-1, AT-1, etc. in NIST SP 800-53) were identified and
discussed. Five or more additional controls from the PM & PL families were
also addressed. Contact information was provided for the audit manager.
Information from the case study was well integrated into the background
material.
IT Security Policies Audit Plan: Audit Objectives5 points
A clear and concise set of audit objectives were presented.
These objectives addressed (and named) all 18 policy & procedures security
controls (e.g. AC-1, AT-1 as listed in NIST SP 800-53).
IT Security Policies Audit Plan: Audit Approach 15
points
The Audit Approach clearly and concisely identified and
described the major elements in the data collection strategy (what data will be
collected, how it will be collected, what will be measured). The data
collection strategy was supported by a checklist (for a document review) or
list of questions (for a survey). The relationship between the audit approach
and the measurement of the effectiveness of the security controls
implementation was explained.
Execution 10 points
Work is professional in appearance and organization
(appropriate and consistent use of fonts, headings, color).
No word usage, grammar, spelling, or punctuation errors. All
quotations (copied text) are properly marked and cited using a professional
format (APA format recommended but not required.)Project #4: IT Audit Policy and Plans
Company Background & Operating Environment
Use the assigned case study for information about “the company.”
Policy Issue & Plan of Action
The corporate board was recently briefed by the Chief Information Officer concerning the
company’s IT Security Program and how this program contributes to the company’s risk management
strategy. During the briefing, the CIO presented assessment reports and audit findings from IT security
audits. These audits focused upon the technical infrastructure and the effectiveness and efficiency of
the company’s implementation of security controls. During the discussion period, members of the
corporate board asked about audits of policy compliance and assessments as to the degree that
employees were (a) aware of IT security policies and (b) complying with these policies. The Chief
Information Officer was tasked with providing the following items to the board before its next quarterly
meeting:
(a) Issue Specific Policy requiring an annual compliance audit for IT security policies as
documented in the company’s Policy System
(b) Audit Plan for assessing employee awareness of and compliance with IT security policies
a. Are employees aware of the IT security policies in the Employee Handbook?
b. Do employees know their responsibilities under those policies?
(c) Audit Plan for assessing the IT security policy system
a. Do required policies exist?
b. Have they been updated within the past year?
c. Are the policies being reviewed and approved by the appropriate oversight
authorities (managers, IT governance board, etc.)?
Your Task Assignment
As a staff member supporting the CISO, you have been asked to research this issue (auditing IT
security policy compliance) and then prepare an “approval draft” for a compliance policy. You must also
research and draft two separate audit plans (a) employee compliance and (b) policy system audit. The
audit policy should not exceed two typed pages in length so you will need to be concise in your writing
and only include the most important elements for the policy. Make sure that you include a requirement
for an assessment report to be provided to company management and the corporate board of directors.
For the employee compliance assessment, you must use an interview strategy which
includes 10 or more multiple choice questions that can be used to construct a webbased survey of all employees. The questions should be split between (a) awareness of
key policies and (b) awareness of personal responsibilities in regards to compliance.
For the policy system audit, you should use a documentation assessment strategy which
reviews the contents of the individual policies to determine when the policy was last
updated, who “owns” the policy, who reviewed the policy, and who approved the policy
for implementation.
Research:
1. Review the weekly readings including the example audit assessment report.
2. Review work completed previously in this course which provides background about the IT Policy
System and specific policies for the case study company.
3. Find additional resources which discuss IT compliance audits and/or policy system audits.
Write:
1. Prepare briefing package with approval drafts of the three required documents. Place all three
documents in a single MS Word (.doc or .docx) files.
2. Your briefing package must contain the following:
Executive Summary
“Approval Drafts” for
o Issue Specific Policy for IT Security Policy Compliance Audits
o Audit Plan for IT Security Policy Awareness & Compliance (Employee Survey)
o Audit Plan for IT Security Policies Audit (Documentation Review)
As you write your policy and audit plans, make sure that you address security issues using
standard cybersecurity terminology (e.g. 5 Pillars of IA, 5 Pillars of Information Security). See the
resources listed under Course Resources > Cybersecurity Concepts Review for definitions and
terminology.
3. Use a professional format for your policy documents and briefing package. Your policy
documents should be consistently formatted and easy to read.
4. Common phrases do not require citations. If there is doubt as to whether or not information
requires attribution, provide a footnote with publication information or use APA format
citations and references.
5. You are expected to write grammatically correct English in every assignment that you submit for
grading. Do not turn in any work without (a) using spell check, (b) using grammar check, (c)
verifying that your punctuation is correct and (d) reviewing your work for correct word usage
and correctly structured sentences and paragraphs.
Submit For Grading
Submit briefing package in MS Word format (.docx or .doc file) for grading using your
assignment folder. (Attach the file.)
Grading Rubric:
Executive Summary for the Policy Briefing Package 10 points
The Executive Summary provided an excellent summary of the policy package’s purpose and contents.
Information about the case study company was well integrated into the summary. Each policy was
individually introduced and clearly explained. The material was well organized and easy to read.
Policy Introduction 10 points
The policy contained an excellent introduction which addressed five or more specific characteristics of
the company’s business, legal & regulatory, and/or enterprise IT environments and addressed the
reasons why employees must comply with this policy. Compliance requirements are addressed and
contact information is provided for questions about the policy.
Policy Content 10 points
The issue specific policy provided excellent (clear and concise) coverage of the following:
policy issue (do required policies exist and have they been properly vetted & approved)
policy solution (auditing all IT security policies to determine compliance with security controls)
applicability (to what and to whom the policy applies)
compliance requirements
point of contact (for more information)
The policy was easy to understand and thoroughly covered the required content.
Security Awareness Audit Plan: Audit Background 10 points
The Security Awareness audit plan contained an excellent background section which identified and
discussed 5 or more risks which drive the requirements and objectives for this audit. IT security controls
for security awareness (AT family of controls from NIST SP 800-53) and related compliance requirements
were identified and discussed. Contact information was provided for the audit manager. Information
from the case study was well integrated into the background material.
Security Awareness Audit Plan: Audit Objectives 5 points
A clear and concise set of audit objectives were presented. These objectives addressed (and named)
each security control in the Awareness & Training (AT) family (as listed in NIST SP 800-53).
Security Awareness Audit Plan: Audit Approach 15 points
The Audit Approach clearly and concisely identified and described the major elements in the data
collection strategy (what data will be collected, how it will be collected, what will be measured). The
data collection strategy was supported by a checklist (for a document review) or list of questions (for a
survey). The relationship between the audit approach and the measurement of the effectiveness of the
security controls implementation was explained.
IT Security Policies Audit Plan: Audit Background 10 points
The IT Security Policies audit plan contained an excellent background section which identified and
discussed 5 or more risks which drive the requirements and objectives for this audit.
The 18 IT security policies & procedures security controls (e.g. AC-1, AT-1, etc. in NIST SP 800-53) were
identified and discussed. Five or more additional controls from the PM & PL families were also
addressed. Contact information was provided for the audit manager. Information from the case study
was well integrated into the background material.
IT Security Policies Audit Plan: Audit Objectives 5 points
A clear and concise set of audit objectives were presented. These objectives addressed (and named) all
18 policy & procedures security controls (e.g. AC-1, AT-1 as listed in NIST SP 800-53).
IT Security Policies Audit Plan: Audit Approach 15 points
The Audit Approach clearly and concisely identified and described the major elements in the data
collection strategy (what data will be collected, how it will be collected, what will be measured). The
data collection strategy was supported by a checklist (for a document review) or list of questions (for a
survey). The relationship between the audit approach and the measurement of the effectiveness of the
security controls implementation was explained.
Execution 10 points
Work is professional in appearance and organization (appropriate and consistent use of fonts, headings,
color).
No word usage, grammar, spelling, or punctuation errors. All quotations (copied text) are properly
marked and cited using a professional format (APA format recommended but not required.)
Table of Contents
Company Overview ……………………………………………………………………………………………………………………… 1
Corporate Governance & Management ……………………………………………………………………………………… 1
Operations ……………………………………………………………………………………………………………………………… 4
Acquisitions …………………………………………………………………………………………………………………………….. 5
Legal and Regulatory Environment …………………………………………………………………………………………….. 6
Policy System ………………………………………………………………………………………………………………………….. 6
Risk Management & Reporting ………………………………………………………………………………………………….. 7
IT Security Management …………………………………………………………………………………………………………… 8
Information Technology Infrastructure ………………………………………………………………………………………….. 9
Enterprise Architecture…………………………………………………………………………………………………………….. 9
Operations Center IT Architecture……………………………………………………………………………………………… 9
Field Office IT Architecture ……………………………………………………………………………………………………… 10
System Interconnections ………………………………………………………………………………………………………… 11
Tables
Table 1. Key Personnel Roster ………………………………………………………………………………………………………. 3
Table 2. Red Clay Renovations Office Locations & Contact Information ……………………………………………… 4
Figures
Figure 1. Red Clay Renovations Organization Chart …………………………………………………………………………. 2
Figure 2. Overview for Enterprise IT Infrastructure ………………………………………………………………………….. 9
Figure 3. IT Architecture for Operations Center …………………………………………………………………………….. 10
Company Overview
Red Clay Renovations is an internationally recognized, awarding winning firm that specializes in the
renovation and rehabilitation of residential buildings and dwellings. The company specializes in updating
homes using “smart home” and “Internet of Things” technologies while maintaining period correct
architectural characteristics. The company’s primary line of business is Home Remodeling Services
(NAICS 236118).
Corporate Governance & Management
Red Clay Renovations was incorporated in the State of Delaware in 1991 and is privately held. (Its stock
is not publicly traded on a stock exchange.)The company maintains a legal presence (“Corporate
Headquarters”) in Delaware to satisfy laws relating to its status as a Delaware corporation. The company
has a five member Board of Directors (BoD). The Chief Executive Officer (CEO) and Chief Financial Officer
(CFO) each own 25% of the corporation’s stock; both serve on the BoD. The CEO is the chair person for
the BoD. The three additional members of the BoD are elected from the remaining stock holders and
each serve for a three year term. The BoD provides oversight for the company’s operations as required
by state and federal laws. Its primary purpose is to protect the interests of stockholders. Under state
and federal law, the BoD has a fiduciary duty to ensure that the corporation is managed for the benefit
of the stockholders (see http://www.nolo.com/legal-encyclopedia/fiduciary-responsibilitycorporations.html). The BoD has adopted a centrally managed “Governance, Risk, and Compliance”
(GRC) methodology to ensure that the corporation meets the expectations of stakeholders while
complying with legal and regulatory requirements.
The company’s senior management includes the Chief Executive Officer (CEO), Chief Financial Officer
(CFO), Chief Operating Officer (COO), Director of Architecture & Construction Services (A&C), Director of
Customer Relations (CR), Director of Human Resources (HR), the Director of Information Technology
Services (ITS), and the Director of Marketing and Media (M&M). The Director of ITS is dual-hatted as the
company’s Chief Information Security Officer (CISO). These individuals constitute the Executive Board for
the company and are responsible for implementing the business strategies, policies, and plans approved
by the BoD. A separately constituted IT Governance Board is chaired by the Chief Operating Officer. The
five directors (A&C, CR, HR, ITS, and M&M) serve as members of the IT Governance board. This board
considers all matters related to the acquisition, management, and operation of the company’s
information technology resources.
The CEO, CFO, and COO have been with the company since it started in 1991. The Directors for A&C, CR,
and HR have over 20 years each with the company. The Director for M&M has ten years of service. The
Director of ITS / CISO has been with the company less than two years and is still trying to bring a
semblance of order to the IT management program – especially in the area of IT security services. This is
a difficult task due to the company’s failure to promptly hire a replacement for the previous director
who retired two years ago.
1
Figure 1. Red Clay Renovations Organization Chart
2
Table 1. Key Personnel Roster
Name & Title
Office
Location
Office Phone
No.
email
James Randell
Wilmington
910-555-2158
jr@redclayrenovations.com
Wilmington
910-555-2150
Irma_Bromley@ redclayrennovations.com
Wilmington
910-555-2152
nr@redclayrenovations.com
Wilmington
910-555-2159
marcus@redclayrenovations.com
Owings Mills
667-555-5000
julia@redclayrenovations.com
Wilmington
910-555-1000
ed@redclayrenovations.com
Owings Mills
667-555-6260
Erwin_Carrington@hq.redclayrenovations.com
Owings Mills
667-555-6370
Eric_Carpenter@hq.redclayrenovations.com
Owings Mills
667-555-6400
an@redclayrenovations.com
Ownings Mills
667-555-6900
rn@redclayrenovations.com
CEO
Irma Bromley
Executive Assistant
to Mr. Randell
Nancy Randell
Chief of Staff
Marcus Randell
CFO
Julia Randell
COO
Edward Randell,
Esq
Corporate Counsel
Erwin Carrington
CIO & Director IT
Services
Eric Carpenter
CISO / Deputy CIO
Amanda Nosinger
Director, Customer
Relations
Rebecca Nosinger
Director, Marketing
& Media
3
Eugene Nosinger
Owings Mills
667-555-8000
en@redclayrenovations.com
Baltimore
443-555-2900
Charles@balt.redclayrenovations.com
Baltimore
443-555-2900
Erica@balt.redclayrenovations.com
Philadelphia
267-555-1200
William@philly.redclayrenovations.com
Philadelphia
267-555-1200
Alison@philly.redclayrenovations.com
Director,
Architecture &
Services
Charles Kniesel
Manager & Architect
in Charge, Baltimore
Field Office
Erica Kniesel
Office Manager &
ISSO, Baltimore Field
Office
William Kniesel
Manager & Architect
in Charge,
Philadelphia Field
Office
Alison KnieselSmith
Office Manager &
ISSO, Philadelphia
Field Office
Operations
Red Clay Renovations has offices in Baltimore, MD, Philadelphia PA, and Wilmington, DE. The contact
information for each location is provided in Table 2.
Table 2. Red Clay Renovations Office Locations & Contact Information
Location
Mailing Address
Phone Number
Baltimore Field Office
200 Commerce Street, Suite 450
443-555-2900
Baltimore, MD 21201
Philadelphia Field Office
1515 Chester Street
4
267-555-1200
Philadelphia, PA 19102
Operations Center (Owings
Mills)
12209 Red Clay Place
Wilmington Office
12 High Street
667-555-6000
Owings Mills, MD 21117
910-555-2150
Wilmington, DE 19801
The Operations Center is the company’s main campus and is located in suburban Baltimore, MD (Owings
Mills). The Owings Mills facility houses the company’s data center as well as general offices for the
company’s operations. These operations include: accounting & finance, customer relations, human
resources, information technology services, marketing, and corporate management. There are
approximately 100 employees at the Operations Center. Day to day management of the Owings Mills
facility is provided by the company’s Chief Operating Officer (COO).
The company’s Chief Executive Officer, corporate counsel, and support staff maintain a presence in the
company’s Wilmington, DE offices but spend most of their time at the Owings Mills operations center.
Field Offices are located in downtown Baltimore and suburban Philadelphia. Each office has a managing
director, a team of 2-3 architects, a senior project manager, a business manager, and an office manager.
Support personnel (receptionist, clerks, etc.) are contractors provided by a local staffing services firm.
Each office operates and maintains its own IT infrastructure.
The company’s architects, project managers, and other support personnel frequently work from
renovation sites using cellular or WiFi connections to access the Internet. Many field office employees
are also authorized to work from home or an alternate work location (“telework site”) one or more days
per week.
Acquisitions
Red Clay acquired “Reality Media Services,” a five person digital media & video production firm in 2015
(NAICS Codes 512110, 519130, and 541430). RMS creates a video history for each residential
construction project undertaken by Red Clay Renovations. RMS also provides Web design and social
media services for Red Clay Renovations to promote its services. RMS employees work primarily out of
their own home offices using company provided equipment (computers, video / audio production
equipment). Each employee also uses personally owned cell phones, laptops, digital cameras, and
camcorders. While RMS is now wholly owned by Red Clay, it continues to operate as an independent
entity. Red Clay senior management is working to change this, however, starting with bringing all IT and
IT related resources under the company’s central management. As part of this change, Red Clay has set
up a media production facility (“Media Studio”) in its headquarters location which includes office space
5
for RMS personnel. The production facility and RMS operations are under the management control of
the Director, Marketing & Media Services.
Legal and Regulatory Environment
The firm is licensed to do business as a general contractor for residential buildings in three states (DE,
MD, PA). The company’s architects maintain professional licensure in their state of residence. The
company’s general counsel is licensed to practice law in Delaware and Maryland. The Chief Financial
Officer is a Certified Public Accountant (CPA) and licensed to practice in all three states.
The company collects, maintains, and stores personal information from and about customers over the
normal course of doing business. This includes credit checks, building plans and drawings for homes, and
information about a customer’s family members which needs to be taken into consideration during the
design and construction phases of a project (e.g. medical issues / disabilities, hobbies, etc.).
When renovations are required due to a medical condition or disability, the company works with health
insurance companies, Medicare/Medicaid, and medical doctors to plan appropriate modifications to the
home and to obtain reimbursement from insurers. This sometimes requires that the company receive,
process, store, and transmit Protected Health Information (PHI) generated by medical practitioners or as
provided by the customer. The company’s legal counsel has advised it to be prepared to show
compliance with the HIPAA Security Rule for PHI for information stored on computer systems in its field
offices and in the operations center.
Red Clay began offering “Smart Home” renovation services in 2005 (NAICS Codes 541310 and 236118).
These services are primarily offered out of the Baltimore and Philadelphia field offices. A large
percentage of the company’s “smart home” remodeling work is financed by customers through the
Federal Housing Administration’s 203K Rehab Mortgage Insurance program. Red Clay provides
assistance in filling out the required paperwork with local FHA approved lenders but does not actually
process mortgages itself. Red Clay does, however, conduct credit checks on prospective customers and
accepts credit card payments for services.
As a privately held stock corporation, Red Clay Renovations is exempt from many provisions of the
Sarbanes-Oxley Act of 2002. But, in certain circumstances, i.e. a government investigation or bankruptcy
filing, there are substantial criminal penalties for failure to protect business records from destruction or
spoliation.
Policy System
The company’s Chief of Staff is responsible for the overall organization and management of the
company’s collection of formal policies and procedures (“policy system”). The company’s policies
provide guidance to employees and officers of the company (CEO, CFO, and the members of the Board
of Directors) with respect to their responsibilities to the company. Policies may be both prescriptive
(what “must” be done) and proscriptive (what “must not” be done). Responsibility for writing and
6
maintaining individual policies is assigned to a designated manager or executive within the company.
Each policy identifies the responsible individual by title, e.g. Director of Human Resources.
The major policy groupings are:
Human Resources
Financial Management
Information Technology
Employee Handbook
Manager Deskbook
Selected policies are published as an Employee Handbook and a Manager’s Deskbook to communicate
them to individual employees and managers and to ensure that these individuals are aware of the
content of key policies which affect how they perform their duties.
Risk Management & Reporting
The company engages in a formal risk management process which includes identification of risks,
assessment of the potential impact of each risk, determination of appropriate risk treatments
(mitigation, acceptance, transfer), and implementation of the risk management strategy which is based
upon the selected risk treatments. For information technology related risks, the CISO working in
conjunction with the IT Governance Board is responsible for identifying and assessing risks.
Corporate-wide, high level risks which could impact the company’s financial performance are disclosed
to shareholders during the annual meeting and in the Annual Report to Investors. For the current year,
the following high level cybersecurity related risks will be disclosed.
1. Cyber-attacks could affect our business.
2. Disruptions in our computer systems could adversely affect our business.
3. We could be liable if third party equipment, recommended and installed by us (e.g. smart home
controllers), fails to provide adequate security for our residential clients.
The company’s risk treatments for cybersecurity related risks include purchasing cyber liability
insurance, implementing an asset management and protection program, implementing configuration
baselines, implementing configuration management for IT systems and software and auditing
compliance with IT security related policies, plans, and procedures.
The corporate board was recently briefed by the Chief Information Officer concerning the company’s IT
Security Program and how this program contributes to the company’s risk management strategy. During
the briefing, the CIO presented assessment reports and audit findings from IT security audits. These
audits focused upon the technical infrastructure and the effectiveness and efficiency of the company’s
implementation of security controls. During the discussion period, members of the corporate board
asked about audits of policy compliance and assessments as to the degree that employees were (a)
7
aware of IT security policies and (b) complying with these policies. The CIO was tasked with providing
audit reports for these items before the next quarterly meeting of the corporate board.
The corporate board also asked the CIO about future plans for improvements to the IT Security program.
The CIO reported that, in the coming year, the CISO will begin implementation of an IT vulnerability
management program. The CIO also reported that the CISO is working with the IT Governance Board to
restart the company’s security education, training, and awareness (SETA) program. SETA activities had
fallen into disuse due to a perceived lack of quality and lack of timeliness (out of date materials). The
CISO has also determined that the System Security Plans for the field offices are out of date and lacking
in important security controls. These plans have been scheduled for update in the near future to ensure
that the company’s risk management strategy for cybersecurity risks is fully implemented.
IT Security Management
The company’s Chief Information Security Officer (CISO) is responsible for providing management
oversight and technology leadership for the company’s Information Technology security program. This
program is designed around the ISO 27001/27002 requirements but is not fully compliant. For cost
reasons, the Chief Information Officer (CIO) has decided not to pursue implementation of CobiT or ITIL
standards for managing IT systems and services. A less costly alternative, using NIST guidance
documents, was approved at the CISO’s suggestion. The CISO’s selected guidance documents include:
NIST SP 800-12 “An Introduction to Computer Security: The NIST Handbook:
NIST SP 800-18 “Guide for Developing Security Plans for Federal Information Systems”
NIST SP 800-53 “Security and Privacy Controls for Federal Information Systems and
Organizations”
NIST SP 800-100 “Information Security Handbook: A Guide for Managers”
NISTIR 7621 “Small Business Information Security: The Fundamentals”
The CISO has determined that the closest fit for the level of security required by law for the company’s
IT systems is the “moderate level” as defined in the FIPS 199/200 standards and specified in NIST SP
800-53 Revision 4. The company has created its own minimum security controls baseline which is used
for developing system security plans.
Under the company’s existing IT Security Management Plan, the following individuals are responsible for
the security of its IT systems.
1. Chief Information Officer: designated approving official for all IT systems certification and
authorization.
2. Chief Information Security Officer: responsible for developing security plans and procedures.
3. Chief Financial Officer: responsible for negotiating and providing oversight for contracts and
service level agreements for IT services.
4. Chief Operating Officer: responsible for approval of and compliance with security plans and
procedures for the company’s IT Operations Center. The COO is the system owner for all IT
systems in the operations center.
8
5. Field Office Manager: responsible for approval of and compliance with security plans and
procedures for his or her field office. The field office manager is the system owner for all IT
systems in his or her field office.
6. Field Office Information Systems Security Officer (ISSO): responsible for day to day
implementation of security plans, processes, and procedures.
Information Technology Infrastructure
Enterprise Architecture
The overview for the enterprise IT architecture for Red Clay Renovations is shown in Figure 2. This
diagram shows the interconnections between the company’s field offices and the operations center.
Each facility-to-facility interconnection is made via a Virtual Private Network (VPN). The VPN connects
the Local Area Networks (LANs) in the operations center and the field offices to the company’s
enterprise network. All IT systems are in the operational phase of the Systems Development Lifecycle.
The company does not have plans at this time to upgrade (“major modification”) or implement (“under
development”) any IT systems.
Figure 2. Overview for Enterprise IT Infrastructure
Operations Center IT Architecture
The Owings Mills facility (see Figure 3) contains the company’s operations (data) center as well as
general offices for the company’s operations. These operations include: accounting & finance, customer
relations, human resources, information technology services, marketing, and corporate management.
9
Figure 3. IT Architecture for Operations Center
Field Office IT Architecture
The company’s corporate headquarters are located in Wilmington, DE. These offices have the same IT
architecture as is used by the field offices in Baltimore and Philadelphia (see Figure 4). The company’s
Chief Executive Officer and support staff maintain a presence in Delaware but spend most of their time
at the Owings Mills operations center. The company’s architects, project managers, and other support
personnel frequently work from renovation sites using cellular or WiFi connections to access the
Internet. Many field office employees, including “Reality Media Services” staff, are also authorized to
work from home or an alternate work location (“telework site”) one or more days per week.
Red Clay’s offices have been remodeled to use the “smart home” and “Internet of Things” technologies
which it installs in the residential buildings that it rehabilitates. These devices have IP addresses and are
connected to the in-office wireless network (WiFi). Each smart device has a controller which can be
accessed via a Web-based interface that runs on the office’s application server (username and password
required). The brand and type of equipment varies. The majority of these devices have little to no
security beyond a password protected Web-based logon. Every Red Clay location also has one or more
conference rooms which provide “smart” podiums, projection and video conferencing technologies, and
wireless network access to both the internal network and the Internet.
All locations use Dell computers for laptops, desktop computers, and servers. The laptops and desktops
were recently upgraded to Windows 10 Enterprise for their operating systems. The servers are running
Windows server 2012. All Windows systems have Symantec Endpoint Protection installed for host-based
security (anti-malware, host-based firewall, host-based intrusion detection).
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Figure 4. “Smart” Office IT Architecture (Baltimore, Philadelphia, Wilmington)
Each field office uses the same logical architecture. This infrastructure consists of a local area network
with both wired and wireless segments. A wiring closet containing the premises router and switches is
located in the office space (labeled “Utilities” in the diagram). The “smart office” and “IoT” devices are
also located within the office suites and are connected via WiFi to the Wireless Access Points and from
there to the office LAN. These devices are individually addressable via their IP addresses. Some have
onboard programmable controllers with Web based interfaces. Others have limited onboard
functionality and must be controlled via a central console (which has an IP address and Web based
interface). The RFID system used to control access to doors has sensor plates affixed to the walls. These
sensors are hard wired to a controller in the utilities closet. This controller connects to the local area
network and can be accessed via a Web based interface using its IP address. Access control for the Web
based interfaces (used for RFID system and “smart” device control) is limited to password protected
logons.
System Interconnections
The Operations Center and the individual Field Offices connect to the Internet via a business grade
Internet Services Provider with a standard Service Level Agreement (as established by the ISP). Systems
interconnections between internal systems and between facilities are certified and approved by the
Chief Information Officer. These interconnections include Virtual Private Network connections between
the Operations Center and the Field Offices over ISP provided networks). The VPN is used to protect the
confidentiality and integrity of information transmitted between IT systems located in the company’s
field offices, its headquarters, and the operations center. (See Information Technology Infrastructure
later in this document for additional information about system interconnections.)
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The operations center and field offices each have their own network infrastructure built on CISCO
branded equipment (Virtual Private Network (VPN), wired and wireless local area networks, wireless
access points, switches, a premise firewall, and intrusion detection system). Offices and server rooms
have RJ-45 wall jacks for 100BaseT “wired” connections to the local area network. Network equipment
serving individual LAN segments is located in locked equipment closets (“wiring closets”) within the
office areas.
The company’s Wide Area Networking (WAN) and Internet services are provided by Verizon Business
services. These services include static IP addresses for the company’s network connections and domain
name service for the company’s primary domain name (RedClayRenovations.com) and multiple third
level domain names (e.g. balt.redclayrenovations.com, philly.redclayrenovations.com, etc.). The
company owns, operates, and manages its own Active Directory server, multiple Web servers, Email
servers, file and print servers, and multiple application /database servers. These servers are accessed via
local area network (LAN) and virtual private network (VPN) connections. The Email and public Web
servers are located in a protected network segment (Demilitarized Zone AKA DMZ) and are accessible
from both internal and external networks.
Verizon provides fiber optic cables to the building demarc. Internally, the company owns the cable
infrastructure and has predominantly Cat 5 cabling inside the buildings. Company owned cabling also
runs from the Verizon owned demarc to a company owned/maintained central wiring closet. This closet
also contains routers and switches serving the internal LANs.
Telephone service is provided to each office building via fiber optic cables (as part of the FiOS business
services). Internal to the buildings, telephone service routes through an Alcatel Private Brach Exchange
(PBX) system over ANSI/TIA/EIA-568-B compliant wiring (predominantly Cat 3 cabling). The PBX system
does not connect to the company’s internal networks.
The company allows employees to bring and use their own personal digital devices (laptops, cell phones,
cameras, etc.) provided that these devices are required to perform their duties. Contract employees are
not allowed to “bring your own device” (BYOD) and will be terminated if they are found to be using cell
phones or personal computers on the company’s premises. Employees carry an RFID enabled “proximity
access” card which they use to access offices and other restricted areas. BYOD devices are NOT allowed
to connect directly to the company’s VPN. These devices are restricted to WiFi access to the Internet
using the company’s wireless access points.
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