Initial Assessments of Safeguarding and Counterintelligence Postures for Classified National Security Information in Automated Systems

EXECUTIVE OFFICE OF THE PRESIDENT
OFFICE OF MANAGEMENT AND BUDGET
WASHINGTON, D.C. 20503
THE DIRECTOR
January 3, 2011
M-11-08
MEMORANDUM FOR THE HEADS OF EXECUTIVE DEPARTMENTS AND AGENCIES
FROM:    Jacob J. Lew  
Director
SUBJECT: Initial Assessments of Safeguarding and Counterintelligence Postures for
Classified National Security Information in Automated Systems
On November 28, 2010, departments and agencies that handle classified national security
information were directed to establish assessment teams to review their implementation of
safeguarding procedures.  (Office of Management and Budget, Memorandum M-11-06,
“WikiLeaks - Mishandling of Classified Information,” November 28, 2010.)  These assessments
were intended to build upon the existing requirement in Executive Order 13526 (“Classified
National Security Information”) for departments and agencies to establish and maintain ongoing
self-inspection programs, in furtherance of the Executive Branch’s comprehensive and enduring
effort to strengthen our safeguarding and counterintelligence postures to enhance the protection
of classified national security information.

Please see the attached memorandum from the Director of the Information Security Oversight
Office (ISOO) and the National Counterintelligence Executive within the Office of the Director
of National Intelligence (ODNI).  Their offices will – consistent with their respective
responsibilities under Executive Order 13526 and Section 1102 of the National Security Act of
1947 (as amended), and in coordination with the Office of Management and Budget – evaluate
and assist agencies to comply with the assessment requirement and provide assistance to agency
assessment teams.  Their support will include periodic on-site reviews of agency compliance
where appropriate.  The attached memorandum calls for agency teams to complete their internal
assessments by January 28, 2011.
Thank you for your cooperation and compliance with the further directions attached to this
memorandum.
AttachmentMEMORANDUM FOR: Senior Agency Officials Designated Under Section 5.4(d) of
Executive Order 13526, "Classified National Security Information"
FROM: Robert M. Bryant
National Counterintelligence Executive
William J. Bosanko
Director, Information Security Oversight Office
SUBJECT: Initial Assessments Pursuant to Office of Management and Budget
Memorandum (M-II-06), "WikiLeaks - Mishandling of Classified
Information," November 28,2010
REFERENCES: A.  Office of Management and Budget Memorandum,
"Initial Assessments of Safeguarding and Counterintelligence
Postures for Classified National Security Information in
Automated Systems," This Date
B. Executive Order 13526, "Classified National Security
Information"  (December 29,2009)
C. Counterintelligence Enhancement Act of 2002, as
amended
Strong counterintelligence and safeguarding postures are necessary to protect classified national
security information.  You have been charged with directing and administering the
implementation of Executive Order 13526 ("Classified National Security Information") by the
head of your department or agency.  As such, you also have a significant role regarding
compliance by your department or agency with  the subject of this memorandum.
On November 28,2010, the Office of Management and Budget directed departments and
agencies that handle classified national security information to establish assessment teams
(consisting of counterintelligence, security, and information assurance experts) to  review their
implementation of safeguarding procedures.  In furtherance of that directive, please find
attached a list of existing requirements and questions your department or agency assessment
team should utilize, as an initial step, to assess the current state of your information systems
security. SUBJECT:  Initial Assessments Pursuant to Office of Management and Budget Memorandum,
"WikiLeaks - Mishandling of Classified Information," November 28,2010
Each initial assessment should be completed by January 28,2011 , and should include the
following with respect to the attached list of self-assessment questions:
1. Assess what your agency has done or plans to do  to address any perceived
vulnerabilities, weaknesses, or gaps on automated systems in the post-WikiLeaks
environment.
2. Assess weakness or gaps with respect to  the attached list of questions, and formulate
plans to resolve the issues or to shift or acquire resources to address those
weaknesses or gaps.
3. Assess your agency's plans for changes and upgrades to current classified networks,
systems, applications, databases, websites, and online collaboration environments ­
as well as for all new classified networks, systems, applications, databases, websites
or online collaboration environments that are in the planning, implementation, or
testing phases - in terms of the completeness and projected effectiveness of all types
of security controls called for by applicable law and guidance (including but limited
to those issued by the National Security Staff, the Committee on National Security
Systems, the National Institute for Standards and Technology).
4. Assess all security, counterintelligence, and information assurance policy and
regulatory documents that have been established by and for your department or
agency.
We look forward  to working with you  to  implement this initial assessment and to ensure that
your agency is best positioned to protect classified national  security information.  We will be in
touch with agencies according to a prioritized, risk-based schedule in order to schedule a
discussion of your initial assessments, as well as  to arrange for subsequent onsite inspections,
where appropriate.
We note that some agencies have also been asked to  respond to an NCIX "Request for
Information on Classified Networks and Systems" dated December 10,2010, in support of
National Security Staff tasking.  We wish  to distinguish that request from the requirements of
this memorandum.
rJ~ J  l,~
Robert M. Bryant William J. Bosanko
Attachment:
As Stated UNCLASSIFIED
UNCLASSIFIED
1
Initial Agency Self-Assessment Program for
User Access to Classified Information in Automated Systems
Each department or agency that handles classified information should assess the agency’s and
its employees’ adherence to the policy issuances noted below, the requirements to safeguard
classified information with an emphasis on their application in automated systems, and any
process the agency has designed to detect purposeful misuse of information technology
systems.  If your agency does not have any of the required programs/processes listed, you
should establish them.
The initial Self Assessment items contained in this document pertain to security,
counterintelligence, and information assurance disciplines, with emphasis on their application
in automated systems.  They are categorized as follows.
1) Management & Oversight
2) Counterintelligence
3) Safeguarding
4) Deter, Detect, and Defend Against Employee Unauthorized Disclosures
5) Information Assurance Measures
6) Education & Training
7) Personnel Security
8) Physical/Technical
 
Policy References – The initial Self Assessment items are drawn from various policy documents
listed here.  
1. EO 12968, Access to Classified Information
2. EO 13526, Classified National Security Information
3. 32 CFR 2001, Implementing Directive for EO 13526
4. Federal Information Security Management Act of 2002
5. EO 12333, United States Intelligence Activities
6. Counterintelligence and Security Enhancements Act of 1994
7. Counterintelligence Enhancement Act of 2002
8. National Security Presidential Directive (NSPD)-54/Homeland Security Presidential Directive
(HSPD)-23, Cybersecurity Policy
9. Presidential Decision Directive/NSC-75, U.S. Counterintelligence Effectiveness:
Counterintelligence for the 21
st
Century
10. Presidential Decision Directive/NSC-24, U.S. Counterintelligence Effectiveness
11. EO 13231, Critical Infrastructure Protection in the Information Age
12. Committee on National Security Systems Policy # 26, National Policy on Reducing the Risk of
Removable Media
13. Committee on National Security Systems Policy #22, Information Assurance Risk
Management PolicyUNCLASSIFIED
UNCLASSIFIED
2
14. Committee on National Security Systems Instruction  #1253, Security Categorization and
Control Selection for National Security Systems, dated October 2009
15. Section 1102 of National Security Act of 1947
16. National Security Directive – 42, National Policy for the Security of National Security
Telecommunications and Information SystemsUNCLASSIFIED
UNCLASSIFIED
3
 
• How does your agency ensure the self-inspection programs evaluate the adherence to
the principles and requirements of the Executive Order 13526 (the Order) and 32 C.F.R.
Part 2001 (the Directive) relative to safeguarding of classified information in automated
systems?
o Do required assessments cover the certification and accreditation of automated
systems with respect to classified information?
o Do required assessments cover safeguarding of classified information specific to
automated systems?
o Are corrective actions developed as indicated in the results/lessons-learned?
o Are deficiencies tracked centrally to enable trend analysis?
o Are security education and training programs updated to reflect common
deficiencies and lessons learned?
o Are agency policies reviewed regularly to address common deficiencies and lessons
learned?
• Does your agency have sufficient measures in place to determine appropriate access for
employees to classified information in automated systems:
o During initial account activation/setup?
o Periodically to determine if access is adequate to perform the assigned tasks or
exceeds those necessary to perform assigned tasks, and adjust them accordingly?
o When IT audit activities indicate that employees are exceeding or attempting to
exceed their permissions?
o When IT audit activities indicate that removable media has been introduced and/or
data is being written to removable media?  and
o When IT audit activities indicate that indicate preset thresholds have been exceeded
or when employees “push” data over one-way transfer devices or when “datamining” is indicated?
• How does your agency ensure that the performance contract or other system used to
rate civilian or military personnel performance includes the designation and
management of classified information as a critical element or item to be evaluated in
the rating of all personnel whose duties significantly involve the creation or handling of
classified information?
• Do supervisors evaluate employee’s acceptance and adherence to the security rules for
physical security, counterintelligence (CI), information assurance (IA), and overall
information protection?  Does this evaluation consider the issues specific to the use of
automated systems?
1. Management & Oversight: UNCLASSIFIED
UNCLASSIFIED
4
• Does your agency have a counterintelligence program?  If so:
o Describe its mission and functions.
o At what level is it funded annually?
o Are the CI program personnel graduates of a counterintelligence training
program for CI professionals at an Intelligence Community (IC)-based training
entity?  If not, when are they scheduled to attend?
o Does the CI program interface with the information assurance element of your
agency?
o To what extent are anomalies that are discovered through your agency’s
information assurance processes brought to the attention of counterintelligence
personnel? To what extent has this occurred over the past twelve months?
• Has your agency identified its high value information and processes that must be
protected?  What process is in place to update and reevaluate these?
• Describe what, if any, process your agency employs to regularly receive information to
identify which of your agency’s information or processes are of priority interest to
adversary collectors?
• Does your agency have a process in place to evaluate its contracts, acquisitions, and
procurements for foreign interest or involvement?  If so, please describe the workings of
that process.
• How does your agency ensure access to classified information in automated systems is
limited to those persons who:  (a) have received a favorable determination of eligibility
from the agency head or their designee,(b) have signed an approved non-disclosure
agreement, and (c) have a need to know the information?
• How does your agency ensure that procedures are in place to prevent classified
information in removable media and other media (back-up tapes, etc.) is not removed
from official premises without proper authorization?
• How does your agency employ procedures to ensure that automated information
systems, including networks and telecommunications systems, that collect, create,
communicate, compute, disseminate, process, or store classified information:  (a)
prevent access by unauthorized persons; and (b) ensure the integrity of the
information?
• How does your agency employ controls to ensure classified information in an
automated systems environment is used, processed, stored, reproduced, transmitted,
and destroyed (removable and other media such as obsolete drives or back-up tapes)
under conditions that provide adequate protection and prevent access by unauthorized
persons and which assure that access to classified information is provided only to
3. Safeguarding:
2. Counterintelligence  UNCLASSIFIED
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authorized persons, and that the control measures are appropriate to the environment
in which the access will occur and the nature and volume of the information?  
• How does your agency ensure that persons who transmit removable and other media
(back-up tapes, etc.) or who use automated systems to transmit classified information
are held responsible for ensuring that intended recipients are authorized persons with
the capability to store classified information?
• How does your agency ensure that classified information transmitted and received via
automated systems or media is accomplished in a manner which precludes
unauthorized access, provides for inspection for evidence of tampering and
confirmation of contents, and ensures timely acknowledgment of the receipt by an
authorized recipient?
• How are need-to-know determinations made in your agency reflected in your
management of automated systems?
• Is classified information that is electronically accessed, processed, stored or transmitted
via automated systems protected in accordance with applicable national policy
issuances identified in the Committee on National Security Systems (CNSS) guidance and
ICD 503, IC Information Technology Systems Security Risk management, Certification,
and Accreditation?
• Do you employ alternative measures to protect against loss or unauthorized disclosure
specific to automated systems?
• Does your agency allow the “modified handling and transmission” of foreign
government information via automated systems?  If so, how do you ensure sufficient
safeguarding by using transmission methods approved for classified information, unless
the method is waived by the originating government?
• How do you ensure that electronic and removable media are properly marked when
they contain classified information?  Do your risk management strategies consider the
use of means to identify electronic media that contain classified information?  
• How do you ensure that classified information is properly marked when used in the
electronic environment?  
• Do you control media access devices and ports on your IT systems to prevent data
exfiltration?
• Have you instituted management measures to thwart deliberate bypass or
circumventing the rules?
• Does your department or agency have a system to ensure that badges, clearances, and
accesses are terminated when an employee no longer requires access?UNCLASSIFIED
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• Do you have an insider threat program or the foundation for such a program?
• Are there efforts to fuse together disparate data sources such as personnel security and
evaluation, polygraph, where applicable, IT auditing or user activities, and foreign
contact/foreign travel information to provide analysts early warning indicators of insider
threats?
• Is there a collaborative effort between CI, IA, security, Inspector General (IG), Office of
General Counsel (OGC), and Human Resources (HR)?  Are these established through
formal agreements, processes and procedures, and/or policies?
• What if anything have you implemented to detect behavioral changes in cleared
employees who do not have access to automated systems?
• Are you practicing “security sentinel” or “co-pilot” policing practices?
• What metrics do you use to measure “trustworthiness” without alienating employees?
• Do you use psychiatrist and sociologist to measure:
o Relative happiness as a means to gauge trustworthiness?
o Despondence and grumpiness as a means to gauge waning trustworthiness?
Specific to national security systems (NSS) that process classified information:
• How do you employ CNSS Policies, Issuances, Instruction, and Advisory Memorandums
to certify and accredit your systems?
• Do you perform Risk assessments and security categorizations in accordance with CNSS,
NIST and FIPS standards?
• What steps has your agency taken to implement the latest version of the NIST SP-800
series guidance on Information Assurance, Risk Management, and Continuous
Monitoring?
• Do you employ NSA and FIPS encryptions to protect classified data in motion and data at
rest?
• Do you collaborate with IA security (ISSM and ISSO) for:
o trends  indicating misuse/abuse,
o a list of Privileged Users (PU) who have administrative access to systems and
networks, and
o a list of PU and General Users who have media-access (read/write/removable
media port) privileges?
• How does your agency examine NSS and evaluate their vulnerability to foreign
interception and exploitation?
• How do you assess the overall security posture of systems and disseminate information
on threats to and vulnerabilities?
4. Deter, Detect, Defend Against Employee Unauthorized Disclosures:
5. Information Assurance Measures: UNCLASSIFIED
UNCLASSIFIED
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• Does your agency review, at least annually, existing risk management processes to
ensure compliance with CNSS policy?
• What steps does your agency take to ensure risk assessments are conducted from an
enterprise perspective, conducting top down assessments and analyzing the compilation
of risks by individual information system owners?
• Does your agency require a formal enterprise-level Plan of Actions and Milestones
(POA&M) containing (i) systemic information systems and organizational security
weaknesses and deficiencies; (ii) risks relating to the identified weaknesses and
deficiencies requiring further mitigation; (iii) specific actions to mitigate identified risks?
• What criteria has your agency established—and how are they enforced—for using
removable media with your NSS?  If your agency permits the use of removable media,
what safeguards are employed and how are they promulgated and trained?  How are
you complying with CNSSP-26?
• If your agency permits the use of removable media:
o How does your agency evaluate the effectiveness for implementing its policy on
the use of removable media in national security systems?
o Does your agency share lessons learned and best practices with respect to its use
of removable media?  What actions does your agency undertake to ensure that
resources are available to implement its removable media policy; incorporating
the content of removable media policy into user training and awareness
programs; publishing and implementing incident response procedures.
o How has it limited the use of removable media on NSS to those operational
environments that require these media to achieve mission success and not
simply for convenience?
o What efforts has your agency undertaken to avoid the use of removable media
by making maximum use of properly configured and secured network shares,
web portals, or cross domain solutions to transfer data from one location to
another?
o What risk management policies has your agency crafted, promulgated, and
implemented to reduce risks to NSS?  How do you verify their implementation?
o Does the agency restrict use to removable media that are USG-owned and that
have been purchased or acquired from authorized and trusted sources?
o Does the agency scan removable media for malicious software using a
department or agency-approved method before introducing the media into any
operational systems?
o Does the agency prohibit automatic execution of any content by removable
media unless specifically authorized by the Chief Info Security Officer?  Are spot
checks conducted or how is compliance verified?
o Does the agency implement access controls (e.g., read/write protections) for
removable media?  How are those controls implemented?
o Does the agency encrypt data on removable media using, as a minimum, the
Federal Information Processing Standard (FIPS) 140-2? UNCLASSIFIED
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o Does the agency prohibit use of removable media for data transfer from the
destination network back to the source network or to any other network unless
the media have been erased, reformatted, and rescanned?  How do you verify
this?
o Does your agency limit the use of removable media to authorized personnel with
appropriate training?  What training is conducted?  When?  How is the adequacy
of training evaluated?  
o Does your agency implement a program to track, account for, and safeguard all
acquired removable media, as well as to track and audit all data transfers? How
are discrepancies handled?  What discrepancies have occurred within CY 2010?
o Does your agency conduct both scheduled and random inspections to ensure
compliance with department/agency-promulgated guidance regarding the use of
removable media?  What is the frequency?  What are the results?
o Does your agency sanitize, destroy, and/or dispose of removable media that
have been used in National Security Systems (NSS) in accordance with a
department or agency-approved method, when the media are no longer
required?  What double-check or verification procedures exist?
• How does your agency ensure that every person who has access to classified
information via automated systems has received contemporaneous training on the
safeguarding of classified information?
• How does your agency implement security education and training program(s) that
ensure employees who create, process, or handle classified information in automated
systems have a satisfactory knowledge and understanding of safeguarding policies and
procedures specific to automated systems?
• What initial, refresher, or specialized training is provided to your personnel specific to
automated systems and appropriate to their duties and responsibilities?
• What are the methods of delivery your organization uses to provide education, training
and awareness programs for CI, and IA to users of automated systems?  (New hire
orientation, semi-annual/annual courses, computer based training?)
• Is CI, security, information security, information systems security, social networking,
incident and/or suspicious activity reporting all covered?
• How does your agency ensure that persons who have access to classified information
understand their responsibility to report any actual or possible compromise or
disclosure of classified information to an unauthorized person(s) to an official
designated for this purpose?
• Are users of automated systems made aware of confirmed violations of the stated
security policy and the ramifications of those actions, in order to demonstrate the
organization’s commitment to its security policies?
6. Education and Training: UNCLASSIFIED
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• Does your training address “need to know” decisions specific to automated systems?
• Does your training include the penalties for providing false or incomplete information to
security investigators during background checks or special security investigations?
• What organizations within your agency manage the security education and training
programs for users of automated systems (CI, Security, IA)?  Is the training separate, or
combined into an integrated, comprehensive and structured CI, Security and IA
program?
• Are CI, Security and IA training materials current, and consolidated into a single
electronic site for ease of reference?
• Are Rules of Behavior/ Acceptable Use agreements signed by individuals (before they
are given facility and network access) that acknowledge they understand the
information that was presented to them during the training?  Are the ramifications for
violations of security policies and procedures discussed?
• In addition to General User Acceptable Use Agreements referenced above, are
Privileged User Roles and Responsibilities Acknowledgment Agreements signed.
(Privileged User:  Network Administrators, Network Security Engineers, Database
Administrators, Software Developers, etc.)
• Have you instituted an “insider threat” detection awareness education and training
program, and if so, how has it affected employee performance or participation in
security programs?
• How do you follow CNSSD-500 & CNSSI 4000 series with regard to IA Education and
awareness training for:
o Infosec professionals
o Senior System Managers
o Systems administrators,
o ISSO’s
o Systems Certifiers, and
o Risk Analysts?
• How do you ensure personnel are informed of CNSS Advisory Memorandums regarding:
o Insider Threats to USG Information Systems
o Web Browser Security Vulnerabilities
o Firewall & Guard protection methods?
o The IA Approach to Incident Management?
• Have you established a comprehensive personnel security program? If so, please
describe your investigative, adjudicative, and continuous evaluation processes.  Do you
train your adjudicators to look for insider threat indicators?
• Have you conducted a trend analysis of indicators and activities of the employee
population which may indicate risky habits or cultural and societal differences other
7. Personnel Security: UNCLASSIFIED
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than those expected for candidates (to include current employees) for security
clearances?
• Do you have a foreign travel/contacts reporting process or system that identifies
unusually high occurrences of foreign travel, contacts, or foreign preference in the
investigative subject pool?
o Does your CI organization have access to the information?
o Do you have mandatory pre-and post-travel briefings for government and
contractors?
o Does your agency have a program to control foreign visitors?
o Do you require reporting of official and non-official travel/contacts?
o Under what circumstances are employees not required to report foreign
contacts?
o If you don’t have a foreign travel reporting process, do you plan to establish
one?  What is the timeframe?
o Do you capture higher than usual occurrence of unauthorized disclosures or
security violations?
o Do you track circumstances whereby certain employee candidates have applied
to multiple departments or agencies seeking employment with access to
classified information?
o Do you capture evidence of pre-employment and/or post-employment activities
or participation in on-line media data mining sites like WikiLeaks or Open Leaks?
• Do you receive regularly updated threat and vulnerability reports that support:
o Your risk management decisions,
o Your training and educations program, and
o Your personnel and physical/technical security programs?
• Do you collaborate among the counterintelligence, personnel security and polygraph
programs for indications of CI activities (both targeted at your agency and from within)?
o Do you have access to:
 Facility and IA certification and accreditation reports, and
 Facility and IA Plans of Action and Milestones (POA&Ms) for resolving
known/identified deficiencies?
• How and to what extent does your agency interface with the FBI of foreign intelligence
concerns? Is your agency familiar with reporting requirements to the FBI under section
811 of the Counterintelligence and Security Act of 1994? Has your agency field an 811
report to the FBI in the previous twelve months?
o Is your department or agency familiar with the Department of Justice CES
requirements relative to media leaks?
o Are you conducting liaison with internal and external investigative activities
related to employee security or suitability issues?
 Monitoring FBI investigations subsequent to 811 referrals, and
 OPM for debarment/removal actions of employees subsequent to
wrongful acts?
• Are all employees required to report their contacts with the media?UNCLASSIFIED
UNCLASSIFIED
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• Has your agency developed annual reports of the status and welfare of the secure
facilities that support the protection of classified information and mission
accomplishment?
• Has your agency conducted a trend analysis for activities and events affecting
information protection at any particular site or a group of sites?
• Do you look for unscheduled maintenance or unusual failures of security hardware
(which might indicate end-of-life deficiencies or insider manipulation)?
• Are Technical Surveillance Countermeasures employed in areas where sensitive information is
discussed?
8. Physical/Technical Security: