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White Paper: Proposed Changes to DFARS to enhance Cyber Security of DoD Info
September 2011
A White Paper providing context on proposed rule changes

Inside:

Background on proposed changes Survey Results Trends of note

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The Community Weighs In On Proposed DFARS Changes

DoD has proposed changes to the Defense Federal Acquisition Regulation Supplement (DFARS) to help enhance security of DoD information in use at contractor facilities. This report provides context on those changes including insights from a recent survey of the federal IT community.

Executive Summary
Respondents to a recent survey of members of the federal IT community provides useful context on the proposed DFARS changes. It was interesting to note, however, that few believe the government is best at protecting information.

Survey Background
In July, CTOvision.com created and distributed a survey on the new proposed Defense Federal Acquisition Regulation Supplement (DFARS) to safeguard unclassified Department of Defense information on contractor networks. After receiving responses from government, industry, and academia, weve summarized feelings and expectations towards the policy below. Of the respondents, 73% said that they were familiar with DFARS, so we believe we hit a good community with our survey. Additionally, about a third of the respondents reported that they were security executives, and another third said they were practitioners. It is good having inputs from both those groupings. A quarter of respondents were in government and three fourths came from industry and academia.

Summary of the proposed DFARS changes:

Draft changes to the Defense Federal Acquisition Regulation Supplement were proposed after the recent string of high profile cyber attacks on defense contractors. Information on Department of Defense networks is protected by DIACAP standards but as of now, protecting information on private networks is left up to the companys discretion. Yet since so much of the governments information storage and R & D is performed by private corporations, DFARS has been put forward in an attempt to

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standardize protection and reporting for contractor networks and systems. Aside from an extensive list of reporting requirements, the following three policies are at the heart of DFARS: a) The Government and its contractors and subcontractors will provide adequate security to safeguard unclassified DoD information on their unclassified information systems from unauthorized access and disclosure. b) Contractors must report to the Government certain cyber incidents that affect unclassified DoD information resident on or transiting contractor unclassified information systems. Detailed reporting criteria and requirements are set forth in the clause at 252.204-70YY. c) A cyber incident that is properly reported by the contractor shall not, by itself, be interpreted as evidence that the contractor has failed to provide adequate information safeguards for DoD unclassified information, or has otherwise failed to meet the requirements of the clause at 252.20470YY. Contracting officers shall consult with a functional manager to assess contract performance. A cyber incident will be evaluated in context, and such events may occur even in cases when it is determined that adequate safeguards are being used in view of the nature and sensitivity of the DoD unclassified information and the anticipated threats.

Views of Respondents from Government

Public sector respondents believed in extending regulation to private industry. 75% answered that government regulations such as FISMA, OMBs M-11-11, NISTIC , and FICAM should apply to all contractors if they hope to work with the government, while 25% felt that companies could secure their data on their own. Most, however, did not believe that the public sector was better at protecting information. 46% of respondents believed that government was better than industry at protecting information systems, 54% thought it was not, and numerous wrote in that it depends on which industry, company, or agency, and on which aspect of protection from what threat. Of government respondents, 83% worked for organizations with policies in place for encryption of data for storage and transmission, network protection and intrusion detection, and cyber intrusion reporting based on NIST Special Pub 800-53 Recommended Security Controls for Federal Information

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Systems and Organizations while only 7% said they did not and 10% did not know. To make DFARS better, the most prevalent suggestion was to get more specific. There were concerns over the government having too broad an influence in contractor systems, overlaps and confusion in rules, departments, and agencies, and insufficiently explicit requirements. Another repeated suggestion was to mandate red team exercises to test the vulnerability of systems.

Views of Respondents from the Private Sector:

In the private sector, faith in government control and regulation was much lower. Only 24% thought the government was better than industry at protecting information, and even then there were heavy reservations with comments such as both are awful and numerous responses that it depends on which industry, which government agency, and what data. Two thirds of respondents feared that their costs would go up if DFARS were to be implemented. At the same time, only 42% felt that adhering to these rules would make their organization or government data any more secure, as opposed to 58% that did not. Reasons given include that some corporations already exceed DFARS standards and that regulations do little to improve fundamental problems of security on the internet such as attribution. Suggesting ways to make DFARS better, industry respondents also cited making definitions and requirements more precise and clarifying terms like adequate just as government respondents did. Private sector respondents also expressed concern for smaller contractors, who may have difficulty implementing the recommendations and go broke trying to comply.

Overall Trends
Both government and industry respondents were concerned about the fuzzy language of DFARS and ambiguity in its implementation. Public sector respondents were much more confident in the governments ability to keep information secure than private sector though both thought it could be

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improved, raising questions on whether government should dictate security measures to industry. While most respondents thought DFARS was generally a good set of guidelines, there were doubts over the cost and implementation. To those that took our survey, thanks! Your inputs will do more than just contribute to this post. We are also providing comments into the formal DFARS process in the hopes of helping government decisionmakers think through the right approach.

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More Reading
For more federal cybersecurity technology and policy issues visit: CTOvision.com- an blog for enterprise technologists with a special focus on Big Data. CTOlabs.com - the respository for our research and reporting on all IT issues. Fedcyber.com - tracking all important federal cybersecurity issues.

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About the Author

Alexander Olesker is a technology research analyst at Crucial Point LLC, focusing on disruptive technologies of interest to enterprise technologists. He writes at http://ctovision.com. Alex is a graduate of the Edmund A. Walsh School of Foreign Service at Georgetown University with a degree in Science, Technology, and International Affairs. He researches and writes on developments in technology and government best practices for CTOvision.com and CTOlabs.com, and has written numerous whitepapers on these subjects. Alex has worked or interned in early childhood education, private intelligence, law enforcement, and academia, contributing to numerous publications on technology, international affairs, and security and has lectured at Georgetown and in the Netherlands. Alex is also the founder and primary contributor of an international security blog that has been quoted and featured by numerous pundits and the War Studies blog of Kings College, London. Alex is a fluent Russian speaker and proficient in French. Contact Alex at AOlesker@crucialpointllc.com

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If you have questions or would like to discuss this report, please contact me. As an advocate for better IT in government, I am committed to keeping the dialogue open on technologies, processes and best practices that will keep us moving forward. Contact: Bob Gourley bob@crucialpointllc.com 703-994-0549 All information/data 2011 CTOLabs.com.

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