ISSUE: SHOULD THE DCI'S LETTER OF PROMULGATION OF THE COMPUSEC SAFEGUARDS BE
Document Type:
Collection:
Document Number (FOIA) /ESDN (CREST):
CIA-RDP89B01354R000100150023-0
Release Decision:
RIPPUB
Original Classification:
K
Document Page Count:
4
Document Creation Date:
December 21, 2016
Document Release Date:
May 13, 2008
Sequence Number:
23
Case Number:
Content Type:
REPORT
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Body:
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ISSUE:
o Should the DCI's Letter of promulgation of the COMPUSEC SAFEGUARDS be
delayed because of Don Latham's letter of 10 May 1985 to NSA and DIA?
GENERAL CONCERN:
o On 10 May 1985 Don Latham signed out a letter to NSA and DIA (with
responses due 31 May 1985) which references the DCI's intent to
promulgate the SAFEGUARDS (this DCI action has been in suspense since
late February; Dr. Davis spoke to you about it last week. An
official letter of promulgation is being developed jointly by
C/SECOM, IHC, and Dr. Davis with intentions to send it through you
to the DCI for signature some time before 24 May 1985).
o In his letter Don Latham notes that C3I's preliminary assessment of
the SAFEGUARDS suggests some potential problems with regard to
implementation within DoD, including some inconsistencies with the
DoD Computer Security Center's Evaluation Criteria. He requests a
review by NSA and DIA to assess the SAFEGUARDS in terms of: (a) the
impact of implementation within DoD and (b) consistency with the DoD
Criteria. He requests these responses from NSA and DIA no later than
31 May 1985 so that he will be prepared to discuss the document with
the IC Staff.
BACKGROUND:
o The SAFEGUARDS document was distributed on 22 January 1985 to NFIC
members and select d government officials with responsibilities
assigned as part of the three package set that included:
the COMPUSEC threat, the technology assessment document, and the
SAFEGUARDS document. In this memorandum of transmittal the DCI
stated: "I intend to direct that the SAFEGUARDS be imposed as
mandatory standards for the 13 'critical' SCI-handling systems by the
end of FY86. These SAFEGUARDS will also be imposed as voluntary
standards for other SCI-handling systems."
o The SAFEGUARDS document was developed as a result of the DDCI's 6 May
1983 letter to the D/ICS which requested the development of a set of
"Community-coordinated minimum acceptable computer security
standards" to be applied to any Community computer networks that
might be developed. The DDCI's letter suggested using the DoD
Computer Security Evaluation Center's criteria as a starting point.
o Per Dr. Davis' recommendation, in a letter of 6 June 1983 D/ICS
responded to DDCI. that "Formal computer standards require five to
seven years to develop, to coordinate, and to introduce effectively
into the infrastructure." A dual approach was recommended in the 6
June 1983 D/ICS letter. This dual approach has been the basic format
of the COMPUSEC effort. This dual approach is:
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-- Set near term priorities for identifying a set of mandatory
standards (later termed SAFEGUARDS at the request of the
COMPUSEC Steering Group) for a limited number of "critical
systems" as a fast track, near term action to reduce the
security risks from a set of vulnerabilities which by any
criteria generate the greatest threat and highest risk (e.g.,
access procedures, security labeling, and accountability) to
information processed by automated systems.
-- Follow through with this effort in a more deliberate pace, to
develop and coordinate the more broadly applicable standard or
standards through the existing mechanism of the Computer
Security Subcommittee of SECOM. These are intended to cover ALL
automated systems processing information derived from sensitive
intelligence methods and sources (i.e., not just "critical
systems").
o The DDCI concurred with this proposed plan of action and issued
supplemental guidance (verbally) that the SAFEGUARDS to be
promulgated must be "doable" and we must be able to "identify the
cost of implementation".
o During the summer and fall of 1983, a 10 member working group under
the auspices of the COMPUSEC effort developed a DRAFT set of
SAFEGUARDS which were based primarily on the DoD Computer Security
Center's Evaluation Criteria (i.e., 21 of 41 SAFEGUARDS were taken
word for word out of the DoD criteria; the remainder covered
physical, personnel, and procedural security areas). These were
issued in draft form on 17 October 1983.
o These 41 SAFEGUARDS were used as the basis for evaluating the
security of the 13 "Critical Systems" and to estimate the costs
associated with fixing the identified problems in the "critical
systems".
o As a result of the "critical system" assessments, CIA and DIA argued
that the DoD Computer Security Criteria and the 41 SAFEGUARDS (which
were based on the DoD criteria) were NOT achievable in existing
systems and that the cost of retrofiting the systems would be
prohibitive. NSA made the same argument via its comments and
complete destruction of the CIRS security plan (also based on the DoD
"
"
critical system
CSC's criteria) which included the NSA
As you recall, DIRNSA refused to have his "critical
systems" evaluated by anyone outside of NSA as part of the DCI's
COMPUSEC effort.
STAT
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STAT
o Based on the "census type data" that we were able to obtain from
security evaluations of the systems at DIA/DoDIIS, CIA, State, and IC
Staff, the COMPUSEC project team redrafted the SAFEGUARDS using
recently retired Chief of Computer Security for DIA/DoDIIS,
as a principal author of the SAFEGUARDS under a contract
to the IC Staff. had 20 years of experience in this
area and was involved in the assessments of ALL of the "critical
systems," except NSA systems, just prior to his retirement. He is
aware of both cost and implementation issues that were inherent in
the 41 SAFEGUARDS issued on 17 October 1983. STAT
o The SAFEGUARDS were redrafted by the COMPUSEC project team and
reduced to a total of 29 SAFEGUARDS. Per the suggestions of the
organizations involved in the assessments, the SAFEGUARDS were
oriented in a scalar fashion to the basic DCID 1/16 modes of
operation (i.e., dedicated, system high, and compartmented) so that
14 SAFEGUARDS are mandatory for systems operated in the DCID-defined
dedicated mode of operation, 25 SAFEGUARDS are mandator for systems
operated in the system-high mode of operation, and all 29 are
mandatory for those systems operated in the compartmented or
multi-level security mode of operation. The SAFEGUARDS document was
informally coordinated with CIA, DIA, State, and OUSD(P).
o The SAFEGUARDS document addressed specific vulnerabilities identified
in the assessments of the 11 "critical systems" in which the authors
(primarily ) were allowed to participate. It
was specifically and intentionally written to be consistent with the
DoD CSC although (per Dr. Davis' guidance) the SAFEGUARDS attempted
to avoid most of the confusing technical jargon that is included in
the DoDC SC .
o While the DoDCSC criteria addresses only the technical aspects of
automated information systems security, the SAFEGUARDS addresses
personnel, physical, procedures, IN RELATION TO THE TECHNICAL
CRITERIA. This included the need for formal accreditation BECAUSE
NONE OF THE CRITICAL SYSTEMS HAVE BEEN APPROPRIATELY ACCREDITED UNDER
THE PROVISIONS OF DCID 1/16.
o DoD has been in involved in an 18 month debate over the DoDCSC
criteria which may be resolved in the next 30-90 days with a
reissuance of tcriteria including some changes that DIA has
specifically requested. The criteria will still be limited to
"technical" criteria. In addition, the original intent of its
development has been diluted to such a point that a whole new set of
security criteria are being developed for networks (probably
available in late 1985), and now the DoD says it must develop
criteria for DBMS which are the main stays of several of the DCI's
critical systems. IT IS NOT CLEAR WHAT THE DoD CRITERIA WILL NOW
COVER WHEN THEY ARE PROMULGATED.
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o Further delays in promulgating the SAFEGUARDS could result in
budgetary impacts (i.e., the COMPUSEC money in the NFIP for FY86-FY88
is justified based on the need to fix "critical systems" IAW the
SAFEGUARDS).
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