Computer Security Controls Should Be Strengthened in the Houston District
July 2000
Reference Number: 2000-20-106
This report has cleared the Treasury Inspector General for Tax Administration disclosure review process and information determined to be restricted from public release has been redacted from this document.
July 18, 2000
MEMORANDUM FOR CHIEF INFORMATION OFFICER
FROM: Scott E. Wilson /s/ Scott E. Wilson
Associate Inspector General for Audit (Information Systems Programs)
SUBJECT: Final Audit Report - Computer Security Controls Should Be Strengthened in the Houston District
This report presents the results of our review of computer security controls in the Houston District. In summary, we found that steps should be taken to strengthen the Houston District’s systems to guard against and detect inappropriate accesses. We made recommendations to improve security controls in the areas of user account management, security surveillance, and physical security.
Management's response was due on July 10, 2000. As of July 18, 2000, management has not responded to the draft report.
Copies of this report are also being sent to the IRS managers who are affected by the report recommendations. Please contact me at (202) 622-8510 if you have questions, or your staff may call Steve Mullins, Director (Systems Security), at (925) 210-7024.
Conclusion
Appendix I - Detailed Objective, Scope, and Methodology
Appendix II - Major Contributors to This Report
Appendix III - Report Distribution List
Advances in information technology have caused the daily activities of the Internal Revenue Service (IRS) to become increasingly automated and inter-linked. These advances, while improving efficiency, have also increased the risk that hackers or dishonest employees could misuse taxpayer data. Recent events have demonstrated the risk of hackers gaining inappropriate access to other government agencies and private businesses. Malicious acts by employees present an even greater risk since they already have access to data via networks. The Houston District has over 800 employees connected to its Windows NT local area network (LAN), approximately 150 of whom have access to taxpayer information through the Examination Returns Control System (ERCS).
The overall objective of this review was to determine whether the Houston District has effective security controls over its computer systems to safeguard information against unauthorized access or use, disclosure, damage, modification, and loss. We reviewed controls over the District’s LAN with emphasis on the ERCS to help define our scope and demonstrate the impact of security weaknesses. This review was part of a series of reviews initiated to assess the overall effectiveness of security controls over the IRS’ information systems.
Results
The District has various computer security controls in place which reduce the risk, to some degree, of unauthorized access and destruction of data. For example, logical access controls, such as user identification and passwords, were properly set up at the minicomputer and LAN level, and logical access to sensitive system areas, such as the ERCS, was correctly limited. In addition, physical access to the working area and computer facilities was properly restricted. However, additional steps in the following areas can further strengthen the computer security program.
Strengthening User Account Management, Security Surveillance, and Physical Security Controls Can Achieve a Higher Level of Security
Following prescribed controls can reduce information systems security weaknesses in the following three areas:
Acting managers were given ERCS approval authority for periods longer than needed, increasing the risk that they could approve inappropriate actions on their own work. In addition, three users who had access to the LAN, but not to the ERCS, were not removed promptly from the LAN after they had left the IRS. We did not identify any inappropriate activity by these three users.
Summary of Recommendations
The Chief Information Officer and IRS executives responsible for systems in the Houston District need to take steps to address the specific weaknesses identified in this report. Actions management should take include: allowing only appropriate system permissions and monitoring the use of the permissions; ensuring system access is promptly removed for departing employees; training and monitoring responsible employees on performing audit trail reviews; and reinforcing backup tape inventory controls.
Management's response was due on July 10, 2000. As of July 18, 2000, management has not responded to the draft report.
The overall objective of this review was to determine whether the Internal Revenue Service’s (IRS) Houston District has effective security controls over its computer systems to safeguard information against unauthorized access or use, disclosure, damage, modification, and loss.
We visited two sites in the District (the headquarters and the Alliance building post-of-duty) during January 2000. We selected the Examination Returns Control System (ERCS) to help define our scope and demonstrate the impact of security weaknesses. In the sites we visited, we reviewed user account management, security surveillance, physical security, and logical access controls for the Windows NT local area network (LAN), minicomputers, and the ERCS. We performed these reviews in accordance with Government Auditing Standards.
Details of our audit objective, scope, and methodology are presented in Appendix I. Major contributors to this report are listed in Appendix II.
The purpose of computer security is to protect an organization’s valuable resources, such as information, hardware, and software. Through the selection and application of appropriate safeguards, security helps the organization meet its mission by protecting its physical and financial resources, reputation, legal position, employees, and other tangible and intangible assets.
The IRS, along with other high-profile government agencies and corporations, is at risk of outsiders’ efforts to break into its LANs. Advances in information technology have caused the daily activities of the IRS to become increasingly automated and inter-linked. These advances, while improving efficiency, have also increased the risk that hackers or dishonest employees could misuse taxpayer data. Malicious acts by employees present an even greater risk since they already have access to networks, in addition to being physically located where the hardware is housed.
Achieving adequate security depends on properly applying several types of controls. These can be categorized into the following four groups:
The Congress recognized the significance of maintaining adequate information system security in the IRS Restructuring and Reform Act of 1998 (RRA 98). This law directs the Treasury Inspector General for Tax Administration (TIGTA) to report to the Congress an assessment of the adequacy and security of the IRS’ information technology. This report is part of TIGTA’s effort to provide that assessment.
The District has various computer security controls in place which reduce the risk, to some degree, of unauthorized access and destruction of data. For example, logical access controls, such as user identification and passwords, were properly set up at the minicomputer and LAN level, and logical access to sensitive system areas, such as the ERCS, was correctly limited. Physical access to the working area and computer facilities was properly restricted.
Additional steps can strengthen the computer security program. Over 800 employees have access to the District’s LAN, approximately 150 of whom have access to taxpayer information through the ERCS. A lack of control over such sensitive data increases the risk that it can be improperly disclosed or misused, possibly to commit fraud or other crimes.
Strengthening User Account Management, Security Surveillance, and Physical Security Controls Can Achieve a Higher Level of Security
Weaknesses in user account management allowed several users higher levels of system access than was appropriate. In addition, security surveillance was not sufficient to detect improper computer activity, and inadequate inventory controls created vulnerabilities in physical security over backup tapes.
User Account Management
User account controls restrict the access of legitimate users to the specific systems, programs, and files they need to conduct their work and prevent unauthorized users from gaining access to computing resources.
Managers granted unneeded access privileges to users and did not remove users from systems when they no longer required access. These conditions occurred because managers were not thoroughly familiar with user account management requirements. In addition, security reviews conducted by users’ managers did not detect the excessive permissions. In some instances, we were unable to determine whether inappropriate usage occurred and, in other instances, we determined it did not occur, as explained further in the following sections.
To reduce the risk of fraud and taxpayer privacy violations, access to IRS systems and applications must be limited to those users who require access to perform their jobs. Employees must be removed timely from systems or applications which they do not need to access. In addition, user activity should be periodically monitored to ensure access to taxpayer data is proper and for official purposes only.
An excessive number of employees had ERCS database research capability.
Intelligent Query (IQ) is software that allows users to research the ERCS database and create customized reports. It can be used when standard ERCS reports do not provide the required data. IQ gives users the capability to create production reports by employee and group. The use of such reports for evaluative purposes is specifically prohibited by law and IRS policy. It also gives users access to tax information for thousands of taxpayers. To prevent unauthorized reports and to protect the personal information of thousands of taxpayers from browsing or unauthorized disclosure, managers must restrict IQ capability to as few employees as possible.
Forty-one ERCS users in the Houston District Examination Division have IQ in their user profile. We believe that 30 of the 41 users (73 percent) have no need for this application. This occurred because users retained this capability after they transferred to other positions or simply no longer needed it. Furthermore, there is no policy defining who should have access to IQ and how this access should be controlled and monitored. Managers did not adequately assess the employees’ need for IQ when conducting reviews of employees’ system accesses and privileges.
Additionally, the use of IQ is not adequately controlled or monitored. To ensure that research of taxpayer data in the ERCS database is for authorized purposes only, all requests for IQ reports should be approved and documented, including a description of the purpose and intended use of the data. There are no procedures requiring requests for IQ reports to be approved and in writing.
It is especially critical to limit and monitor the use of IQ because managers have no audit trails to detect unauthorized use. The ERCS application does not capture IQ activity and the UNIX system captures only system-level activity, such as when a user enters or exits IQ. Because of the insufficient audit trail information, we were unable to detect whether evaluative production reports or any other inappropriate usage of IQ occurred.
Temporary ERCS permissions for acting managers were not adequately controlled.
Examination group managers may temporarily grant employees acting for them the authority to approve actions, or update (close) cases. The manager can grant this approval through the ERCS menu, or in the manager’s absence, another manager can submit a written request to the ERCS coordinator who will grant the approval permission. This authority should be delegated for the shortest possible period of time and revoked upon the manager’s return.
On one day during our review, January 5, 2000, six revenue agents had temporary approval permission. Three of the six were given the permission for a 90-day period, longer than the duration of the managers’ absences. In one of these three instances, the group manager did not provide or request the permission; instead, the revenue agent made the request to the ERCS coordinator on his own behalf. In addition to the six agents above, two other revenue agents were granted permanent approval authority by the ERCS coordinator instead of temporary permission, and another two agents were granted temporary authority to take actions such as closing cases and updating case statutes.
Currently, the ERCS cannot systemically prevent acting managers from taking actions on their own cases. Inappropriate actions taken with temporary update or approval authority could lead to violations of taxpayer rights and embezzlement.
Managers did not ensure that approval authority was granted for the shortest period of time. Managers did not periodically review audit trail records to identify employees using temporary approval or update permission to take actions on their own cases.
Users were not timely removed from the LAN.
Three of 43 Examination Division employees who separated from the Division during 1999 continued to have access to the LAN up to 4 months after their separation dates. In one case, the manager was aware that a form was required to remove the employee from the LAN, but had not timely completed it. In the other two instances, managers were not aware that the form was needed. None of the three were ERCS users or had access to any other applications containing taxpayer or sensitive data, and none accessed the LAN after separating. These employees also had Integrated Data Retrieval System access that was appropriately cancelled prior to their separation dates.
Security Surveillance
Audit trails are the primary control for detecting improper activity on computer systems. Generally, they should show who took the action, what they did, where they did it, and when. Although there is no audit trail for IQ, audit trails were available to detect activity on the LAN, on the minicomputers, and on the ERCS application running on the minicomputers. However, we noted weaknesses relating to all three audit trails.
The Internal Revenue Manual and other guidelines require that system administrators generate and distribute audit trails to appropriate managers for review. Functional security coordinators should review audit trails to ensure system integrity and to report anomalies. Security administrators should also review audit logs at least weekly and provide reports of security problems to the system administrators, the Information Systems Chief, and functional managers. User managers should ensure that audit trails are appropriately reviewed.
On the LAN, the operating system generates a security log, which contains audit trail information. There was no documentation that any reviews of this information had taken place.
The audit trails were deactivated for the three minicomputers on which the ERCS resides. This situation occurred because the system lacks the hardware resources to run the audit trail and the ERCS application at the same time. The audit trail slowed the system response time to a level that did not adequately service the users.
For the ERCS application running on the minicomputers, there were no scheduled reviews of the audit trail information, and any reviews that may have been done were not documented. The functional coordinator could have run audit trail reports that show requested actions, record updates, permissions, approvals, employee records and researched records.
Audit trails were run for the remaining minicomputers. However, there were no regularly scheduled reviews or monitoring of system administrator activities. Additionally, there was no documentation of any reviews that may have taken place. Officials advised that these reports are difficult to understand, and neither the vendor nor National Office staff have been able to assist them.
Although there are clear requirements for gathering and reviewing audit trail information, the requirements are often not specific regarding how to conduct the reviews and how they should be documented. In the absence of these guidelines, District management did not devise interim or local procedures to ensure the reviews were completed and adequately documented.
The ability to log and monitor computer system activities is important because it provides a means to detect improper activities that could occur if other system controls are circumvented. When audit trails are not running or properly monitored, the ability to identify offenders and pinpoint weaknesses to prevent future occurrences is lost.
Physical Security
Physical security is the most fundamental form of information systems control and is important because it is the first barrier in preventing unauthorized access and loss of taxpayer information. Physical security controls are implemented to protect sensitive areas housing information systems equipment or data. Sensitive areas requiring physical controls include computer rooms, communication wire closets, and areas housing essential support equipment, such as power control panels, air conditioning units, communication equipment, and magnetic media storage.
Controls over backup tapes need strengthening.
Information systems capture electronic data on magnetically charged disks and tapes, commonly referred to as magnetic media. Effective media management ensures accountability and accessibility of disks and tapes to operate the IRS’ information systems. Without proper media protection, critical taxpayer data could be lost or compromised.
There is no library log for recording the removal and return of tapes to the library. However, library personnel are required to document the removal of magnetic media. In addition, admittance to the tape library should be restricted to only those with a need to access the tapes to prevent unauthorized access to taxpayer information. Although the room is secured with a cipher lock, the E-mail administrator, who has no need to access the tapes, works in the room.
Managers did not identify and ensure that weaknesses in tape library controls were addressed and corrected.
When records are not kept or are not current and access is not restricted, the risk of unauthorized disclosure of taxpayer information and not detecting missing tapes increases.
Recommendations
The Chief Information Officer and IRS executives responsible for systems in the Houston District need to take steps to address the specific weaknesses identified in this report.
Management's response was due on July 10, 2000. As of July 18, 2000, management has not responded to the draft report.
User Account Management
Security Surveillance
Physical Security
Like other IRS offices, the Houston District’s systems contain large amounts of sensitive information, and can be accessed by a large number of employees. Strengthening computer security controls can help ensure that access to the sensitive information is restricted to only those having a legitimate business need to use the information.
Implementation of our recommendations could reduce: 1) opportunities to improperly manipulate or destroy data; 2) opportunities for theft; and 3) the risk of improper use or disclosure of sensitive taxpayer data.
Appendix I
Detailed Objective, Scope, and MethodologyThe overall objective of this review was to determine whether the Internal Revenue Service’s (IRS) Houston District has effective security controls over its computer systems to safeguard information against unauthorized access or use, disclosure, damage, modification, and loss. The following four control areas each contain an overall objective, sub-objectives, and tests for the particular area.
USER ACCOUNT MANAGEMENT
The overall objective of this control area was to determine if management has implemented sufficient user account management controls to ensure that access to taxpayer data on the Local Area Network (LAN) is limited to authorized individuals on a need-to-know basis.
Sub-objective I: Determined if management has implemented procedures in line with the security policy of providing access based on the individual’s demonstrated need to view, add, change or delete data.
Sub-objective II: Determined if management has established procedures to ensure timely action relating to requesting, establishing, issuing, suspending and closing of ERCS and LAN user accounts.
Sub-objective III: Determined if management has a control process in place to periodically review and confirm access rights.
SECURITY SURVEILLANCE
The overall objective of this control area was to determine whether controls are effective to ensure that all activity involving access to and modifications of sensitive or critical files is logged, effectively reviewed, and responded to if incidents occur.
Sub-objective I: Determined if controls are effective over audit trails to ensure that all activity involving access to and modifications of sensitive or critical files is logged.
Sub-objective II: Determined if controls over audit trails ensure that they are effectively reviewed and access is limited to a need-to-know.
Sub-objective III: Determined if controls ensure prompt and appropriate responses to security incidents.
PHYSICAL SECURITY AND ENVIRONMENTAL CONTROLS
The objective of this control area was to evaluate the effectiveness of physical and environmental security controls over the LANs and selected sensitive and mission-critical applications for physically restricting access to computer hardware and adequately safeguarding taxpayer data.
Sub-objective I: Determined whether local policies and procedures on physical security are sufficient to limit access to LAN system servers and workstations and to safeguard EDP equipment from theft or loss.
Identified the security controls in place regarding restricting entrance into workspaces and the computer room. Identified how maintenance/cleaning personnel are allowed into the computer room.
Sub-objective II: Determined whether entrances to computer facilities and functional users’ work spaces are properly secured and protected to ensure only authorized personnel are allowed to enter.
A. Identified locations for all workstations, obtained building layouts and conducted walk-throughs of computer rooms and some work spaces in the Alliance and headquarters buildings to identify all computer hardware related to the application being reviewed. Determined if physical entrances to spaces are restricted to authorized personnel.
B. Determined if the District’s computer room maintains a low profile and physical identification is limited. Determined if the computer room’s entrances and construction meet standards and specifications. Determined whether the location prohibits direct, unrestricted accesses through the outside or a public hallway. Determined whether a computer room entrance log is used regularly and properly controlled.
Sub-objective III: Determined whether security controls over telecommunication points of entry for the applications and its workstations are adequate to provide a trusted path for sensitive data flow.
Sub-objective IV: Evaluated the adequacy of the fire protection system related to LAN/ WAN systems within the computer room.
Sub-objective V: Determined whether the environmental equipment is adequate to protect computer hardware from damage.
Sub-objective VI: Determined whether the back-up policy and procedures are adequate to ensure continuity of service in the event of a system/application disruption of operation.
A. Interviewed appropriate IS personnel and obtained the details of the back-up procedure for the ERCS application and its data.
B. Determined if the back-up process is periodically tested to ensure that it performs as intended and whether the back-up tapes are periodically reviewed to ensure that the data are accurate and complete.
C. Conducted a walk-through of the off-site location for back-up tapes to evaluate the security level of the site. Ensured access is restricted to authorized personnel, a back-up log is maintained, and the site is not identified as a tape library.
D. Conducted a reconciliation of the back-up tape inventory for the ERCS application to ensure inventory accurately reflects the back-up inventory listing.
E. Discussed the procedure for ensuring the back-up process is working properly.
F. Determined the procedure for loading data from the back-up tapes and whether this procedure has been tested and works as intended.
IDENTIFICATION, AUTHENTICATION AND ACCESS CONTROLS
The overall objective of this control area was to evaluate whether logical security controls were effectively installed to protect the integrity and confidentiality of the information processed, transmitted and stored.
Sub-objective I: Evaluated whether logical controls were adequately implemented to identify and authenticate users of the LAN operating system:
Sub-objective II: Evaluated the adequacy of logical controls to prevent unauthorized access to and modification of system software.
Sub-objective III: Evaluated the adequacy of controls to prevent unauthorized access and modification to the LAN, its resources and the information it transmits.
Appendix II
Major Contributors to This ReportScott E. Wilson, Associate Inspector General for Audit (Information Systems Programs)
Stephen Mullins, Director
Richard T. Hayes, Audit Manager
Gerald H. Horn, Audit Manager
Bret Hunter, Senior Auditor
Joan Raniolo, Senior Auditor
Billy Benge, Auditor
David Hodge, Auditor
Midori Ohno, Auditor
Una Smith, Auditor
Theodore Tomko, Auditor
Appendix III
Report Distribution ListDirector, Office of Security and Privacy Oversight IS:SPO
Director for Legislative Affairs CL:LA
Office of Management Controls CFO:A:M
Office of Chief Counsel CC
Director, Office of Program Evaluation and Risk Analysis M:O
National Taxpayer Advocate C:TA
Director, Information Technology – Midstates Area IS:F:MS
Director, Houston District
Audit Liaison: Chief Information Officer IS