Enforcement, not flawlessness, key to security

Surviving a security audit requires good policies, procedures and practices — and auditors look unfavorably on federal agencies with policy and procedural deficiencies, a security compliance official said today at a conference in Washington, D.C.

Todd Fitzgerald, systems security officer for United Government Services, a claims processing company for Medicare and Medicaid Services, said federal officials cannot avoid information security deficiencies altogether, but they should strive to make auditors scour for deficiencies.

"How far does the auditor have to go before he finds something?" Fitzgerald asked. "Let's move it down into practices," he suggested. Far better for an auditor to find a few contractors are not adhering to an agency's security policies than to find that agency officials have poor security policies and no procedures for enforcing those policies in actual practice.

United Government Services, which processes $30 million in claims a year, is subject to more than 400 security requirements, Fitzgerald said. In that environment, company officials issue no security policies that they cannot enforce, he said.

Fitzgerald suggested that audience members do the same, and he offered some additional advice. He said federal officials should not feel pressured to eliminate all information security risks, because to do so would be too expensive. "Sometimes accepting risk is a perfectly good thing to do," he said.

A sharp rise in reported security incidents is not always a bad thing either, he said. "It shows people are paying attention."

Fitzgerald warned, however, that federal officials should keep security plans up to date for each of their information systems. "The first documents that auditors ask for are the system security plans," he said.

Fitzgerald spoke at a conference sponsored by the Computer Security Institute, a group that offers computer and network training.