Orange County Grand Jury • 2016-2017 • Agency Response
Response to: County of Orange Executive Office

Orange County's Digital Data: Is It Protected From Cyber Attack?*

Published: September 12, 2017 10 pages
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Findings and Recommendations 8 findings

F1
Orange County government entities are prime cyber targets, under constant cyber attack, and both public and private information held by these entities are not adequately protected. Disagrees partially with this finding. Orange County is no more a target than Response: other government agencies. Government agencies are continuously targeted for various reasons such as hacktivism and cyber crime. It is not correct to say the information is not adequately protected. Information systems are protected and monitored. Orange County has a robust Cyber Security Deterrence Program. Continuous improvement in this area is being addressed by way of county wide cyber security assessments and the establishment of a County Cyber Security Joint Task Force (CSJTF). The CSJTF was established to standardize security controls and methodologies across all County departments.
Related Recommendations (1)
R1
The county should review, update and standardize all employee and contractor exit procedures to ensure the security of the countywide sensitive information by 12/31/2017. The recommendation has not yet been implemented but it will be Response: implemented. The recommendation will be implemented through the CSJTF and the publishing of the County Cyber Security Policy and Process Manual. By charter, the CSJTF is not due to provide the IT Executive Council the final product for approval until March 30, 2018.
F2
The county is subject to many types of cyber attacks but phishing currently represents the highest risk to the county's sensitive information. Agrees with this finding. Response:
Related Recommendations (1)
R2
OCIT should select, acquire and direct the implementation of computer- based data loss prevention capability by 12/31/2017. This recommendation has been implemented. OCIT has begun the process of Response: implementing county-wide Data Loss Prevention (DLP) through our email system. The policies are designed to prevent transmission of sensitive information such as credit card information, personally identifiable information (PII) and health record information. The County Privacy Officer is leading the effort to develop the DLP policies in collaboration with County departments.
F3
Some county cyber attacks come through third-party vendors, who may not always be sufficiently protected. Agrees with this finding. Third party vendors are now vetted for their security Response: protocols during the procurement cycle and when third party vendors "enter" the County's network, they are subject to County standards.
Related Recommendations (1)
R3
The county should review, update and standardize all employee and contractor exit procedures to ensure the security of countywide sensitive information by 12/31/2017. This recommendation requires further analysis. Access control reviews are Response: currently underway as part of the countywide cyber security assessments. Review of access controls determines the individuals with access to data and systems and whether there is still a need to have access to said data and systems. The County is expected to have all departments complete these cyber security assessments
F4
The county has taken a number of steps to safeguard its digital data and systems against cyber attack, but there are a number of actions generally recognized as cybersecurity best practices that still need to be implemented. Partially disagrees with this finding. As mentioned earlier, cybersecurity Response: measures are ever evolving; which best practices the County will choose to implement will be based on County-specific evaluations. The Board of Supervisors has authorized a dedicated team to lead county security planning, deployment and recovery. The County adheres to best practice both in the commercial and government space and continues to evaluate changes to our protocols as new measures are available.
Related Recommendations (1)
R4
OCIT should establish a countywide cybersecurity working group by 12/31/2017. Participation should be mandatory for County of Orange agencies that report to the CEO and highly recommended for other county government entities. This recommendation has been implemented. The CJSTF serves as the working Response: group for cyber security.
F5
County financial records do not separate out cybersecurity as a line item, making it hard to determine what resources are being allocated in the area and therefore what additional funds are needed. Disagrees with this finding. OCIT maintains an Enterprise Security budget which Response: is meant to cover cyber security management, maintenance, assessment, incident response, and new initiatives.
Related Recommendations (1)
R5
OCIT should develop a formal five-year cybersecurity strategic plan as a separate part of the IT Strategic Plan in the next county strategic plan. This recommendation has been implemented. OCIT does have a formalized Response: road map for Cyber Security to take the County to a point of maturity where the County is implementing National Institute of Standards and Technology (NIST) Cyber Security and Risk Management Frameworks (RMF) and other appropriate measures.
F6
Cooperation among county agencies is currently limited due to organizational and cultural issues including the visibility of available centralized OCIT cybersecurity support, the inward focus of county agencies and the fact that the influence of the BOS to compel collaboration is largely limited to county agencies with appointed heads that report to the county CEO and, to a lesser degree, the county agencies with elected heads. Respondent disagrees with this finding. The CJSTF represents a major shift in Response: this culture as it is made up of representatives from all County departments, including elected and appointed departments. Additionally, both elected and non-elected department heads sit on the IT Executive Council – a Board of Supervisors-approved IT governance body. OCIT Enterprise Security has seen an increased interest over the past 18 months in sharing information and improved collaboration in the areas of mitigating risks of cyber threats and responding to cyber security incidents. Departmental leadership understands the County is stronger when all departments collaborate to reduce the risks associated with cyber threats as evidenced by the participation on the CSJTF and the IT Executive Council.
Related Recommendations (1)
R6
OCIT should finalize a mandatory county incident response plan with procedures for individual agency exceptions and present it to the appropriate oversight bodies and BOS for approval by 7/1/2018. This recommendation has not yet been implemented but will be Response: implemented in the future. OCIT has developed and implemented a Cyber Incident Response Plan (CIRP) that has been tested. OCIT Enterprise Security plans to adopt the CIRP, through a vote of the CSJTF, prior to March 30, 2018.
F7
OCIT has an effective team in place for addressing cybersecurity deficiencies, but it is only in the formative stages of implementing centralized standards and best practices for cybersecurity. Outside OCIT's control, county government agencies are taking advantage of the county's cybersecurity initiatives to different degrees. Agrees with this finding. Response:
Related Recommendations (1)
R7
The county should include in its 2018-19 IT Strategic Plan the identification, documentation and categorization by risk of county digital sensitive information. This recommendation has not yet been implemented but it will be Response: implemented in the future. This issue is best addressed through a strategic level initiative to centralize management of data exfiltration points and establishment of a formal Data Classification Policy. The CJSTF is the strategic level mechanism that will address how sensitive digital information is to be classified and handled.
F8
IT employees across county government are largely untrained and uncertified in cybersecurity, especially at the agency level. Staffing for cybersecurity is challenging due to outdated county cybersecurity job classifications and salary levels, as well as lengthy county hiring processes, particularly for those agencies requiring extensive background checks. Disagrees partially with this finding. Some departments do provide security Response: specific training such as the County's Health Care Agency. OCIT Enterprise Security is addressing this issue, by increasing the IT security training budget from $30,000 to $50,000 annually. With respect to non-IT employees, the County implemented mandatory online Cyber Security Awareness Training (CSAT) in January of 2017. Since implementation, over 90% of County employees have competed the online CSAT. The CISO agrees with the finding that it is challenging to hire cyber security professionals for the reasons stated in this finding. RECOMMENDATIONS AND RESPONSES:
Related Recommendations (1)
R8
The county should annually review and update the amount and types of county cyber insurance based on the annual county risk analysis. This recommendation has been implemented. County Risk Management Office Response: currently reviews and manages the cyber insurance policy for the County.

* This report's PDF did not contain easily extractable text and required Optical Character Recognition (OCR) for analysis. There may be minor errors in the extracted findings and recommendations due to OCR limitations with scanned documents.