⚠️ Translation Notice: This content has been automatically translated. The original English text is the official version. Translation may contain errors.
⚠️ Este contenido ha sido traducido automáticamente. El texto original en inglés es la versión oficial. La traducción puede contener errores.
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.
Related Recommendations (1)
R1
The county should establish a periodic cybersecurity audit schedule for all third-party vendors that connect to county networks and systems by 12/31/2017.
F2
The county is subject to many types of cyber attacks but phishing currently represents the highest risk to the county’s sensitive information.
Related Recommendations (1)
R2
OCIT should select, acquire and direct the implementation of computer-based data loss prevention capability by 12/31/2017.
F3
Some county cyber attacks come through third-party vendors, who may not always be sufficiently protected.
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.
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.
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.
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.
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.
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.
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.
F7
OCIT has an effective team in place for addressing cybersecurity deficiencies, but 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.
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. R. 8. The county should annually review and update the amount and types of county cyber insurance based on the annual county risk analysis.
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. Penal Code §933 and §933.05 require governing bodies and elected officials to which a report is directed to respond to findings and recommendations. Responses are requested from departments of local agencies and their non-elected department heads. RECOMMENDATIONS In accordance with California Penal Code Sections §933 and §933.05, the 2016-2017 Grand Jury requires (or, as noted, requests) responses from each agency affected by the recommendations presented in this section. The responses are to be submitted to the Presiding Judge of the Superior Court. Based on its investigation “Orange County’s Digital Data: Is It Protected from Cyber Attack?” the 2016-2017 Orange County Grand Jury makes the following 18 recommendations:
No recommendations for this finding
Additional Recommendations 6
These recommendations are not explicitly linked to specific findings.
-
R9OCIT should implement cybersecurity training and professional certification of all county IT analysts having cybersecurity as a part of their job responsibilities by 7/1/2018.
-
R10OCIT should establish audit and test procedures to periodically, but no less than every two years, gauge the effectiveness of training and other cybersecurity measures by 7/1/2018.
-
R11The county should establish separate budget line items for cybersecurity expenses and capital investments for the 2018-2019 budget.
-
R12The county should implement the use of regional cooperative agreements for the acquisition of all cybersecurity related products and services by 7/1/2018.
-
R13The county should review and update IT job classifications and salary levels to reflect the current job market by 6/30/18. R. 14. The county should develop a succession plan covering cybersecurity-critical positions by 6/30/18 to provide for continuity of these positions. R. 15. Procedures for updating and patching all county software and systems that have been established by OCIT for the shared services program should be made mandatory for all county departments and agencies that report to the CEO, and recommended for all other county government entities by 6/30/18. R 16. OCIT should draft and implement standardized procedures for mandatory use of full disk encryption and remote find/wipe capabilities for countywide mobile devices by 7/1/2018. R. 17. OCIT should establish standardized procedures for IT’s examination and removal of all sensitive information on county digital devices, prior to their removal from county premises through transfer, sale, scrap or reuse by 12/31/17. R. 18. OCIT should establish standardized procedures for conducting periodic cybersecurity vulnerability and penetration testing by 12/31/19. REQUIRED RESPONSES The California Penal Code §933 requires the governing body of any public agency which the Grand Jury has reviewed, and about which it has issued a final report, to comment to the Presiding Judge of the Superior Court on the findings and recommendations pertaining to matters under the control of the governing body. Such comment shall be made no later than 90 days after the Grand Jury publishes its report (filed with the Clerk of the Court). Additionally, in the case of a report containing findings and recommendations pertaining to a department or agency headed by an elected County official (e.g. DA, Sheriff, etc.), such elected County official shall comment on the findings and recommendations pertaining to the matters under that elected official’s control to the Presiding Judge with an information copy sent to the Board of Supervisors. Furthermore, California Penal Code Section §933.05 (a), (b), (c), details, as follows, the manner in which such comment(s) are to be made: (a) As to each Grand Jury finding, the responding person or entity shall indicate one of the following: (1) The respondent agrees with the finding (2) The respondent disagrees wholly or partially with the finding, in which case the response shall specify the portion of the finding that is disputed and shall include an explanation of the reasons therefore. (b) As to each Grand Jury recommendation, the responding person or entity shall report one of the following actions: (1) The recommendation has been implemented, with a summary regarding the implemented action. (2) The recommendation has not yet been implemented, but will be implemented in the future, with a time frame for implementation. (3) The recommendation requires further analysis, with an explanation and the scope and parameters of an analysis or study, and a time frame for the matter to be prepared for discussion by the officer or head of the agency or department being investigated or reviewed, including the governing body of the public agency when applicable. This time frame shall not exceed six months from the date of publication of the Grand Jury report. (4) The recommendation will not be implemented because it is not warranted or is not reasonable, with an explanation therefore. (c) If a finding or recommendation of the Grand Jury addresses budgetary or personnel matters of a county agency or department headed by an elected officer, both the agency or department head and the Board of Supervisors shall respond if requested by the Grand Jury, but the response of the Board of Supervisors shall address only those budgetary /or personnel matters over which it has some decision making authority. The response of the elected agency or department head shall address all aspects of the findings or recommendations affecting his or her agency or department. Comments to the Presiding Judge of the Superior Court in compliance with Penal Code section §933.05 are required from: Responses Required: Orange County Board of Supervisors (Findings F.1. – F.8.; Recommendations R.1 - 18.). Responses Requested: County Executive Office (Findings F.1. – F.8.; Recommendations R.1., R.3., R.7., R.8.,
-
R16OCIT should draft and implement standardized procedures for mandatory use of full disk encryption and remote find/wipe capabilities for countywide mobile devices by 7/1/2018. R. 17. OCIT should establish standardized procedures for IT’s examination and removal of all sensitive information on county digital devices, prior to their removal from county premises through transfer, sale, scrap or reuse by 12/31/17. R. 18. OCIT should establish standardized procedures for conducting periodic cybersecurity vulnerability and penetration testing by 12/31/19. REQUIRED RESPONSES The California Penal Code §933 requires the governing body of any public agency which the Grand Jury has reviewed, and about which it has issued a final report, to comment to the Presiding Judge of the Superior Court on the findings and recommendations pertaining to matters under the control of the governing body. Such comment shall be made no later than 90 days after the Grand Jury publishes its report (filed with the Clerk of the Court). Additionally, in the case of a report containing findings and recommendations pertaining to a department or agency headed by an elected County official (e.g. DA, Sheriff, etc.), such elected County official shall comment on the findings and recommendations pertaining to the matters under that elected official’s control to the Presiding Judge with an information copy sent to the Board of Supervisors. Furthermore, California Penal Code Section §933.05 (a), (b), (c), details, as follows, the manner in which such comment(s) are to be made: (a) As to each Grand Jury finding, the responding person or entity shall indicate one of the following: (1) The respondent agrees with the finding (2) The respondent disagrees wholly or partially with the finding, in which case the response shall specify the portion of the finding that is disputed and shall include an explanation of the reasons therefore. (b) As to each Grand Jury recommendation, the responding person or entity shall report one of the following actions: (1) The recommendation has been implemented, with a summary regarding the implemented action. (2) The recommendation has not yet been implemented, but will be implemented in the future, with a time frame for implementation. (3) The recommendation requires further analysis, with an explanation and the scope and parameters of an analysis or study, and a time frame for the matter to be prepared for discussion by the officer or head of the agency or department being investigated or reviewed, including the governing body of the public agency when applicable. This time frame shall not exceed six months from the date of publication of the Grand Jury report. (4) The recommendation will not be implemented because it is not warranted or is not reasonable, with an explanation therefore. (c) If a finding or recommendation of the Grand Jury addresses budgetary or personnel matters of a county agency or department headed by an elected officer, both the agency or department head and the Board of Supervisors shall respond if requested by the Grand Jury, but the response of the Board of Supervisors shall address only those budgetary /or personnel matters over which it has some decision making authority. The response of the elected agency or department head shall address all aspects of the findings or recommendations affecting his or her agency or department. Comments to the Presiding Judge of the Superior Court in compliance with Penal Code section §933.05 are required from: Responses Required: Orange County Board of Supervisors (Findings F.1. – F.8.; Recommendations R.1 - 18.). Responses Requested: County Executive Office (Findings F.1. – F.8.; Recommendations R.1., R.3., R.7., R.8., R.11., R.12., R.13., R.14., R.15.). Orange County Information Technology (Findings F.1. – F.8.; Recommendations R.2., R.4., R.5., R.6., R.9., R.10., R.15., R.16., R.17., R.18.). REFERENCES Akamai. (2016). State of the Internet Security Q3 2016 Report. Akamai. Chuang, E. (2017). It's Not You, It's Your Vendor: The Hidden Doorway to Phishing Attacks. Legaltech news, p. 2. Retrieved 5 1, 2017, from http://www.legaltechnews.com/id=1202784938919/Its-Not-You-Its-Your-Vendor-The- Hidden-Doorway-to-Phishing- Attacks?kw=It%27s%20Not%20You%2C%20It%27s%20Your%20Vendor:%20The%20 Hidden%20Doorway%20to%20Phishing%20Attacks&et=editorial&bu=Law%20Technol ogy%20News& Grimes, R. A. (2017). 9 new hacks coming to get you. CSO Online, p. 9. Retrieved 2 21, 2017, from http://www.csoonline.com/article/3171741/security/9-new-hacks-coming-to-get- you.html?idg_eid=c35b9224fe3bb5b632c1e442a73c4ba4&email_SHA1_lc=fa902d91c1a ebeb660bfe968f17cf604cb88c00b&utm_source=Sailthru&utm_medium=email&utm_ca mpaign=CSO%20Update%202017-02-2 ISO - ANSI. (2010). The Financial Management of Cyber Risk. New York: Internet Security Alliance (ISA)/American National Standards Institute (ANSI). Retrieved 2 21, 2017, from https://share.ansi.org/khdoc/Financial+Management+of+Cyber+Risk.pdf Kaspersky. (2015). The Threats From Within: How educating your employees on cybersecurity can protect your company. Kaspersky Lab. Retrieved 2 17, 2017, from usa.kapersky.com Masunga, S. (2017). Target settles with states over breach. Los Angeles Times. Retrieved May 24, 2017 Microsoft. (2016). Intelligent Security: Using Machine Learning to Help Detect Advanced Cyber Attacks. Microsoft Corporation. Retrieved 2 2, 2017, from https://www.microsoft.com/en- us/security/intelligence?&WT.srch=1&WT.mc_id=AID__SEM_Ta9wKfnh National Association of Corporate Directors. (2017). Cyber-Risk Oversight. Washington, D.C., USA: National Association of corpoprate Directors. Retrieved 2 23, 2017, from https://www.nacdonline.org/cyber NIST. (2012). Computer Security Incident Handling Guide - Special Publication 800-61. National Institute of Standards and Technology, Computer Security, Information Technology Laboratory. Gathersberg: National Institute of Standards and Technology. Retrieved 1 30, 2017, from http://nvlpubs.nist.gov/nistpubs/SpecialPublications/NIST.SP.800-61r2.pdf NIST. (2013). Glossary of Key Information Security Terms. (R. Kisswel, Ed.) Retrieved 1 19, 2017, from National Institute of Standards and Technology: http://dx.doi.org/10.6028/NIST.IR.7298r2 NIST. (2016). Small Business Information Security: The Fundamentals. Gaithersburg: National Institute of Standards and Technology Applied Cybersecurity Division, Information Technology Laboratory. Retrieved 1 30, 2017, from https://doi.org/10.6028/NIST.IR.7621rl Orange County Information Technology. (2017). Implementing a Shared Services Strategy for Information Technology. Santa Ana: OCIT. Retrieved 5 13, 2017, from http://cams.ocgov.com/Web_Publisher/Agenda01_24_2017_files/images/O00316- 001666A.PDF Phishlabs. (2017). 2017 Phishing Trends & Intelligence Report: Hacking the Human. Charleston: ECrime Management Strategies, Inc. Retrieved 2 27, 2017, from https://pages.phishlabs.com/rs/130-BFB- 942/images/2017%20PhishLabs%20Phishing%20and%20Threat%20Intelligence%20Rep ort.pdf?mkt_tok=eyJpIjoiWkdVeFpESTRNek0xTm1GaCIsInQiOiJNdFhhR1pvcUVmb XdXaDhrMWE5KzVvV25qRDRodzFKdnlsK3NyeGVZWWNkYTN0SDErR2pWVG81 YTJ1Tzdvc05zOH Plante Moran. (2014). Enterprise Resource System Security Audit Report (Phase 3.0, 4.0 and 5.0 Combined). Cerritos: Plante Moran. Ponemon Institute. (2016). 2016 Cost of Data Breach Study. Ponemon Institute. Privacy Rights Clearinghouse. (2017). Chronology of Data Breaches. Retrieved from Privacy Rights Clearninghouse: https://www.privacyrights.org/data-breaches PwC. (2016). Key findings from the Global State of Information Security 2017. PwC. Retrieved 2 17, 2017, from http://www.pwc.com/gx/en/issues/cyber-security/information-security- survey/assets/gsiss-report-cybersecurity-privacy-possibilities.pdf SANS Institute. (2017). Cyber Security Trends: Aiming Ahead of the Target to Increase Security in 2017. Bethesda: SANS Institute. Retrieved May 12, 2017, from https://www.sans.org/reading-room/whitepapers/analyst/cyber-security-trends-aiming- target-increase-security-2017-37702 Straight, J. (2017). Key Cyber Trends Dominating the Early 2017 Discourse. Retrieved 3 6, 2017, from Legaltech News: http://www.legaltechnews.com/id=1202780585472/5-Key- Cyber-Trends-Dominating-the-Early-2017- Discourse?kw=5%20Key%20Cyber%20Trends%20Dominating%20the%20Early%2020 17%20Discourse&et=editorial&bu=Law%20Technology%20News&cn=20170306&src= EMC-Email&pt=Daily%20Ale Symantec. (2016). Internet Security Threat Report. Symantec. Retrieved 1 20, 2017 U.S. Department of Justice. (2015). Best Practices for Victim Response and Reporting of Cyber Incidents. Cybersecurity Unit, Computer Crime and Intellectual Property Section, Criminal Division. U.S. Department of Justice. Retrieved 1 30, 2017, from https://www.justice.gov/sites/default/files/criminal- ccips/legacy/2015/04/30/04272015reporting-cyber-incidents-final.pdf Verizon. (2016). 2016 Data Breach Investigations Report. Verizon. APPENDICES
Conclusions 1
-
CL1Maintaining cybersecurity in Orange County’s multifaceted government is a complex challenge. Information that defines citizens’ identity, health, finances, communications, and personal and commercial transactions is all saved on computers connected to the internet or stored in the cloud and is subject to cyber attack. The resources allocated to cybersecurity are determined by the degree of risk the county is willing to assume. To further its cybersecurity initiatives, the county has a number of oversight bodies, an Enterprise Security Group with an experienced CISO, CPO and staff; a firewall-protected centralized network with email monitoring and intrusion protection. Anti-virus endpoint protection and data backup programs are in place in most county departments and agencies as well. There are also a number of county cybersecurity initiatives in development. The county can draw from many national and state government cybersecurity bodies and programs to leverage its efforts. One of five California multiagency fusion centers devoted to identifying and issuing cybersecurity threat alerts is located in Orange County. Although much has been done, the OCGJ has identified areas for further work to sufficiently protect county information. This requires sustained support by the BOS, as well as elected and appointed agency heads. Areas of need include countywide risk assessment and mitigation, trained cybersecurity staff, digital security management, increased collaboration countywide, third-party vendor management, and documented centralized procedures.
No Responses Found 1
Government entities assigned to respond to this report. No response documents have been linked in our database.
Orange County
County