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Position Sensitivity - Based on Security Clearance and/or Information Technology (IT) Systems Access Level or Responsibility for Security Oversight on Assigned Information Systems (IS)


Overview

Finding ID Version Rule ID IA Controls Severity
V-32342 PE-02.02.01 SV-42679r3_rule Medium
Description
RULE OVERVIEW: Failure to identify Information Assurance (IA) Positions of Trust (e.g., SA, ISSM, ISSO) and associated Position Sensitivity level (e.g., special-sensitive, critical-sensitive, noncritical-sensitive) could result in an incumbent of such position having Privileged Access to, or Security Oversight of an information system without the required investigative and adjudicative prerequisites. Information Assurance (IA) Positions of Trust are specifically those positions with Privileged Access to an Information System(s) or positions with responsibility for Oversight of Systems Security. Examples are System Administrators (SA), Information System Security Managers (ISSM), Information System Security Officers (ISSO), Information System Engineers, System Designers… Formerly Information Assurance (IA) Positions of Trust were identified under the Automated Data Processing (ADP) (AKA: Information Technology (IT)) Position Categories and Criteria IAW the DoD 5200.2-R, Personnel Security Program, January 1987. These long established legacy ADP Categories were not included in the update to the DOD PERSEC Program contained in the DOD Manual 5200.02, Procedures for the DoD Personnel Security Program (PSP), dated 3 April 2017. This possible gap in policy guidance has been addressed with the USD(I) PERSEC Policy authority and they are aware of the omission of the guidance in the PERSEC update. Pending further direction from the USD(I) their guidance is to use the Office of Personnel Management (OPM) Position Designation Tool (PDT): Because many organizations have institutionalized the ADP Categories and Criteria, the use of the legacy ADP position methodology for identification and designation of position sensitivity for IT Positions of Trust may still be used in lieu of the PDT for compliance with requirements in this STIG Rule. LEGACY ADP CRITERIA EXPLAINED: With regard to the former ADP/IT level designations the following general rules apply: Critical-Sensitive Positions ADP-I positions. Those positions in which the incumbent is responsible for the planning, direction, and implementation of a computer security program; major responsibility for the direction, planning and design of a computer system, including the hardware and software; or, can access a system during the operation or maintenance in such a way, and with a relatively high risk for causing grave damage, or realize a significant personal gain (e.g., privileged access and/or systems security oversight). Noncritical-Sensitive Positions ADP-II positions. Those positions in which the incumbent is responsible for the-direction, planning, design, operation, or maintenance of a computer system, and whose work is technically reviewed by a higher authority of the ADP-I category to insure the integrity of the system. Non-sensitive Positions ADP-III positions. All other positions involved in computer activities. In establishing the categories of positions, other factors may enter into the determination, permitting placement in higher or lower categories based on the Agency's judgement as to the unique characteristics of the system or the safeguards protecting the system. RELEVANT BACKGROUND INFORMATION: All positions (military and civilian) must be categorized as either special-sensitive, critical-sensitive, noncritical-sensitive or non-sensitive based on a variety of duties associated with a specific position. Two of the most prevalent criteria used within the DoD for determination of position sensitivity are the level of security clearance (e.g., TS, S, C) and/or the level of access granted to information technology (IT) systems (e.g., privileged access (AKA: system administrator (SA)) or non-privileged access (AKA: authorized user access)). The significance of designating position sensitivity is the type of background investigation the incumbent of a particular position must undergo (e.g., Tier 5 investigation (formerly SSBI) or Tier 3 investigation (formerly NACI/ANACI)) is based upon the designated position sensitivity. FOLLOWING ARE A SUMMARY OF CHANGES TO: 1. TYPES OF INVESTIGATIONS AND 2. AUTOMATED DATA PROCESSING (ADP) (AKA: INFORMATION TECHNOLOGY (IT)) POSITION CATEGORIES: As of 1 October 2016, the former investigations known as NACLAC, ANACI, NACI, BI, MBI, SSBI, etc. are no longer conducted. These investigations have been replaced by the Office of Personnel Management (OPM) with a "Tiered" Investigation process. The new investigations are grouped in five levels or tiers and investigations are now referred to as Tier 1-5, with Tier 5 (T-5) being the most stringent investigation and Tier 1 (T-1) being the least stringent. The update to the DOD PERSEC Program contained in the DOD Manual 5200.02, Procedures for the DoD Personnel Security Program (PSP), dated 3 April 2017 does not contain any implementing guidance for moving from the former investigations to the new Tiered Investigations. As previously mentioned, the update to the DOD PERSEC Program also does not include Automated Data Processing (ADP) (AKA: Information Technology (IT)) Position of Trust categories used for designation of position sensitivity IAW the former DoD 5200.2-R, January 1987, which was replaced by the updated Manual. Again, these gaps in policy guidance have been addressed with the USD(I) PERSEC Policy authority and they are aware of the omission of the guidance in the PERSEC update. POSITION DESIGNATION TOOL (PDT): Both of the policy gaps may or may not be addressed in the next PERSEC Manual update but pending formal documented guidance the USD(I) has provided verbal/email guidance to the DISA Traditional Security STIG SME to direct DoD users to use the Office of Personnel Management (OPM) Position Designation Tool (PDT). Position Designation Tool URL: https://www.opm.gov/suitability/suitability-executive-agent/position-designation-tool/ The PDT contains Information Technology (IT) Position criterial similar to the former ADP criteria. Proper input of IT position responsibility criteria into the PDT will calculate and provide both a position sensitivity designation and the associated background investigation requirement. Use of the PDT will provide essentially the same outcome as the guidance using former ADP designations (e.g., position sensitivity designation and type of background investigation required). This assertion assumes job related IT criteria are correctly input into the PDT. It is important to understand the DoD position sensitivity designations as detailed in the Personnel Security Program (PERSEC) Manual are based primarily on designated security clearance requirements and other specified job related duties and responsibilities. While similar, the OPM position designation system differs from the DoD PERSEC guidance. The difference is that while the OPM Position Designation Tool (PDT) determines position sensitivity based upon security clearance requirements and/or the duties of a position (or contractually established set of duties); it also applies the estimated impact levels (e.g., high, medium and low) of these assigned duties to National Security along with calculated/assigned risk levels. These additional “subjective” factors are key determining criteria for position sensitivity in the PDT. To reduce subjectivity in the position sensitivity determination process security personnel must understand the following terms when using the PDT: NATIONAL SECURITY refers to those activities which are directly concerned with the foreign relations of the United States, or protection of the Nation from internal subversion, foreign aggression, or terrorism. A NATIONAL SECURITY POSITION, includes any position in a department or agency, the occupant of which could bring about, by virtue of the nature of the position, a material adverse effect on the national security. NON-SENSITIVE POSITIONS/DUTIES are PUBLIC TRUST POSITIONS or duties and responsibilities that are unrelated to National Security. *Keep in mind that the primary mission of most DoD organizations concerns the national security. Hence all Information Technology (IT) positions involved with the DoD (DISN) cyber security mission should be considered as National Security Positions. These positions are for instance System Administrators (SA), Information System Security Managers (ISSM), Information System Security Officers (ISSO), Information System Engineers and other related positions, which are detailed in the DoD 8570.01-M, Information Assurance Workforce Improvement Program, 19 December 2005, Incorporating Change 4, 11/10/2015. Again, the outcome of using the PDT should generally be the same as the DoD requirements for position sensitivity under the legacy ADP/IT position criteria but the individual using the tool must have a thorough understanding of the duties and impact of the duties of each position being assessed for the PDT outcome to be appropriate and consistent with the DoD standards. It is important to limit the subjectivity involved with these determinations and provide consistent results throughout the DoD. PRIVILEGED ACCESS TO INFORMATION TECHNOLOGY SYSTEMS: A key legacy consideration for IT positions of trust is that any position where an incumbent has “Privileged Access” to an information system should normally be designated as a Critical-Sensitive position. *This is regardless if there is a corresponding requirement for the incumbent to have a TS security clearance or not. Generally the TS clearance is the predominate requirement for designation of position sensitivity as critical-sensitive; however, where there is a requirement for either a secret, confidential, or no security clearance and the incumbent also has a requirement for privileged access to an information system – the privileged access criterial will make the position critical-sensitive with a Tier-5 (T-5) background investigation requirement. Hence, the privileged access criteria consideration is beyond the typical noncritical-sensitive or non-sensitive position designations associated with only a secret, confidential, or no security clearance normally resulting in a Tier-3 (T-3) or lower level investigation requirement. PRIVILEGED ACCESS DEFINED: The following definition of privileged access is excerpted from the DoD 8570.01-M, Information Assurance Workforce Improvement Program. Privileged Access is an authorized user who has access to system control, monitoring, administration, criminal investigation, or compliance functions. Privileged access typically provides access to the following system controls: -Access to the control functions of the information system/network, administration of user accounts, etc. -Access to change control parameters (e.g., routing tables, path priorities, addresses) of routers, multiplexers, and other key information system/network equipment or software. -Ability and authority to control and change program files, and other users’ access to data. -Direct access to operating system level functions (also called unmediated access) that would permit system controls to be bypassed or changed. -Access and authority for installing, configuring, monitoring, or troubleshooting the security monitoring functions of information systems/networks (e.g., network/system analyzers; intrusion detection software; firewalls) or in performance of cyber/network defense operations. ************end of Privileged Access Definition********* CONNECTION OF TIER 3 (T-3) AND TIER 5 (T-5) INVESTIGATIONS TO IT POSITIONS OF TRUST AND SECURITY CLEARANCES: With regard to Information Technology (IT) positions of trust for protection of DoD Information Network (DoDIN) (AKA: Defense Information System Network (DISN)) assets, the two most applicable levels of investigation are Tier 3 and Tier 5. Tier 3 investigations are those generally associated with Non-Critical Sensitive positions of trust (confidential or secret security clearance or former ADP II level duties). Examples of the former investigations which are now Tier 3 are NACLAC and ANACI. Tier 5 investigations are those generally associated with Special-Sensitive and/or Critical Sensitive positions of trust (TS clearances with or w/o SCI/SAP or Privileged Access to IT / former ADP I level duties). The former investigation that is now Tier 5 is the SSBI. In the next several years it is reasonable to expect that a combination of both the old investigations and the new Tier investigations will be found within the DoD until the new investigations are completely phased-in for current personnel. Therefore, security managers must continue to be familiar with both the old and new investigations. CONTRACTOR PERSONNEL AND IT POSITIONS OF TRUST: While Contractor personnel are not formally assigned to positions within DoD organizations, the type of investigation required is like DoD civilians and military personnel in that it is based on security clearance requirements for each type or category of work performed and IT system access levels. Specific IT system duties/access levels along with security clearance requirements and associated investigations must be detailed in the applicable Statement of Work and/or DD Form 254 (Contract Security Specification). THE BOTTOM LINE: In summary the association of DoD position sensitivity designation and required investigations is based on IT position of trust system access levels and/or level of responsibility for oversight of systems security in conjunction with the level of security clearance required for military or civilian positions *or type of work performed by contractor employees. The relationship of position sensitivity to clearances, duties and investigations can be delineated as follows: *Special-Sensitive and/or Critical- Sensitive positions: Legacy IT-1 (ADP-1) Privileged users (SAs) and/or ISSM/ISSO and/or TS or TS-SCI clearance SSBI/Tier 5 investigations **Non-Critical Sensitive positions: Legacy IT-2 (ADP-2) Privileged users under direct supervision of an ADP-1 vetted Privileged user and/or Authorized users and/or Confidential or secret security clearance NACLAC, ANACI, NACI/Tier 3 investigations ***Non-Sensitive positions: Legacy IT-3 (ADP-3) and no security clearance; Not Applicable for current DoD cyber security positions REFERENCES: DoDI 8500.01, March 14, 2014, SUBJECT: Cybersecurity: Paragraph 10.a-e (Cybersecurity Workforce) DoD 8570.01-M, Information Assurance Workforce Improvement Program, 19 December 2005, Incorporating Change 4, 11/10/2015: Paragraphs C1.4.4.4., C1.4.4.5., C3.2.4.1.2., C3.2.4.2., C3.2.4.8., C4.2.3.1.2., AP1.15 and AP 1.22. CJCSI 6510.01F, INFORMATION ASSURANCE (IA) AND SUPPORT TO COMPUTER NETWORK DEFENSE (CND); Enclosure A, paragraphs 7 and 11., Enclosure B, paragraph 2.l. and Enclosure C, paragraph 4. and paragraph 10. NIST Special Publication 800-53 (SP 800-53), Rev 4, Controls: PE-2(1), PS-1, PS-2, PS-3, PS-6(1) and PS-6(2). DoD 5200.22-M (NISPOM), Incorporating Change 2, 18 May 2016, Chapter 2, Section 2 and Chapter 8, Section 3, paragraph 8-302.a. Personnel Security. (Current) DoD Manual 5200.02, Procedures for the DoD Personnel Security Program (PSP), April 3, 2017, Paragraphs 4.1.a.(2)(m), (r), (u) & (3)(a), (b), (c) and 4.1.b. Civilian Personnel, 4.2. Military Personnel, 4.3. Contractors, 4.4. Consultants. (Legacy) DoD 5200.2-R, Personnel Security Program, Chapter 3, paragraphs C3.1., C3.1.2.1.1.7., C3.1.2.1.2.3., C3.1.3., C.3.2, C3.3 and C3.6.15, and Appendix 10. OPM/National Background Investigations Bureau URL: https://www.opm.gov/suitability/ https://nbib.opm.gov/ https://nbib.opm.gov/hr-security-personnel/requesting-opm-personnel-investigations/#url=5.0 *POSITION DESIGNATION TOOL: https://www.opm.gov/suitability/suitability-executive-agent/position-designation-tool/ The Joint Personnel Adjudication System (JPAS) and the Defense Information System for Security (DISS). Once fully deployed, DISS will replace JPAS to serve as the system of record to perform comprehensive personnel security, suitability and credential eligibility management for all military, civilian, and DOD contractor personnel. These databases reflect position sensitivity, security clearance information and ADP/IT information for vetted individuals.
STIG Date
Traditional Security Checklist 2020-08-26

Details

Check Text ( C-40791r12_chk )
Request to see and then review organization manning documents (e.g., Joint Table of Distribution and Allowances (JTD)) and position descriptions that indicate the position sensitivity and assigned duties of all information technology (IT) related positions (military and government civilian).

Check #1. Check to ensure that Information Assurance (IA) (AKA: Cyber Security) Positions of Trust are identified for each civilian and military position and/or duties in which an employee has cyber security related duties (e.g., privileged access or security oversight) on a DoDIN Information System (IS) (e.g., SIPRNet or NIPRNet). This is required for members of the DoD workforce conducting Cyber Security (AKA: Information Assurance (IA)) functions in assigned duty positions. Examples include but are not limited to: Information System Security Manager (ISSM), Information System Security Officer (ISSO), and System Administrator (SA). These are positions consistent with the IA Workforce Improvement Program (DoD 8570.01-M) that are required to be trained, certified and specially vetted for integrity and loyalty.

Check #2. Check all IA designated positions (e.g., system administrators (SA), information system security manager (ISSM), information system officers (ISSO)) and other information technology related positions to ensure that manning documents/position descriptions reflect designation of the position sensitivity level (e.g., special-sensitive, critical-sensitive or noncritical-sensitive).

Request to see and then review the statements of work and/or DD Forms 254 (Contract Security Specification) for Contractors supporting the organization.

Check #3. Check to ensure that Information Assurance (IA) (AKA: Cyber) Security Positions of Trust are identified for each contractor employee set of duties contained in statements of work for all positions or duties in which an employee has cyber security related duties (e.g., privileged access or security oversight) on a DoDIN Information System (IS) (e.g., SIPRNet or NIPRNet). This is required for members of the DoD workforce conducting Cyber Security (AKA: Information Assurance (IA)) functions in assigned duty positions. Examples include but are not limited to: Information System Security Manager (ISSM), Information System Security Officer (ISSO), and System Administrator (SA). These are positions consistent with the IA Workforce Improvement Program (DoD 8570.01-M) that are required to be trained, certified and specially vetted for integrity and loyalty.

Check #4. Review all contracting documents for contracts where contractor employees will have access to either the NIPRNet, SIPRNet or both. For unclassified contracts the statement of work should be reviewed and for classified contracts both the statement of work and the DD Form 254 (Contract Security Specification) should be reviewed. Ensure the documents indicate security clearance levels and/or information system technology related duties for each contractor position or set of duties.
The specific purpose of the contract document review is to check to ensure that background investigation requirements along with security clearance and ADP (AKA: IT) position sensitivity level requirements are detailed for each type of work or specified “position” where applicable. The investigation requirements are to be based upon both the security clearance and ADP (AKA: IT) position sensitivity level. This is essentially the same process as designation of position sensitivity for military and DoD civilian positions.

NOTES:

1. The intent of checks 1 and 2 is to ensure IA/Cyber Security positions of trust are specifically identified and to ensure position sensitivity is officially designated for each IA position based on security clearance and ADP/IT level; not necessarily to ensure it is correctly designated for each assigned incumbent of a position.

2. The intent of checks 3 and 4 is to ensure IA/Cyber Security positions of trust are specifically identified within SOWs and/or DD Forms 254 and that background investigation requirement (s) are specified in contract documents for identified IA positions based upon security clearance and position ADP/IT levels; not necessarily to ensure it is correctly designated for each individual contractor assigned to a specified position or set of duties.

3. If an organization is choosing to no longer use the former ADP/IT position sensitivity levels then reviewers should not assess based on the ADP/IT criteria. In this instance the organization/site must demonstrate use of the OPM Position Designation Tool (PDT) and maintain documentation to reflect the use of the PDT for each Information Assurance (IA)/Cyber Security position.

TACTICAL ENVIRONMENT: The check is applicable for fixed (established) tactical processing environments and is also applicable to a field/mobile environment.
Fix Text (F-36255r7_fix)
Fix #1. Ensure that official organizational manning records identify and reflect Information Assurance (IA) (AKA: Cyber Security) Positions of Trust for each civilian and military position and/or duties in which an employee has cyber security related duties (e.g., privileged access or security oversight) on a DoDIN Information System (IS) (e.g., SIPRNet or NIPRNet). This is required for members of the DoD workforce conducting Cyber Security (AKA: Information Assurance (IA)) functions in assigned duty positions. Examples include but are not limited to: Information System Security Manager (ISSM), Information System Security Officer (ISSO), and System Administrator (SA). These are positions consistent with the IA Workforce Improvement Program (DoD 8570.01-M) that are required to be trained, certified and specially vetted for integrity and loyalty.

Fix #2. Ensure all IA designated positions (e.g., system administrators (SA), information system security manager (ISSM), information system officers (ISSO)) and other information technology related positions identified in manning documents/position descriptions reflect designation of the position sensitivity level (e.g., special-sensitive, critical-sensitive or noncritical-sensitive).

Fix #3. ensure that Information Assurance (IA) (AKA: Cyber) Security Positions of Trust are identified for each contractor employee set of duties contained in statements of work for all positions or duties in which an employee has cyber security related duties (e.g., privileged access or security oversight) on a DoDIN Information System (IS) (e.g., SIPRNet or NIPRNet). This is required for members of the DoD workforce conducting Cyber Security (AKA: Information Assurance (IA)) functions in assigned duty positions. Examples include but are not limited to: Information System Security Manager (ISSM), Information System Security Officer (ISSO), and System Administrator (SA). These are positions consistent with the IA Workforce Improvement Program (DoD 8570.01-M) that are required to be trained, certified and specially vetted for integrity and loyalty.

Fix #4. Ensure for unclassified contracts the statement of work (SOW) and for classified contracts both the SOW and the DD Form 254 (Contract Security Specification) that the documents indicate security clearance levels and/or information system technology related duties for each contractor position or set of duties. The specific purpose is to ensure contract documents contain background investigation requirements along with security clearance and ADP (AKA: IT) position sensitivity level requirements. These must be detailed for each type of work or specified “position” where applicable. The investigation requirements are to be based upon both the security clearance and ADP (AKA: IT) position sensitivity level. This is essentially the same process as designation of position sensitivity for military and DoD civilian positions.

NOTE:

If an organization chooses to no longer use the legacy ADP/IT position sensitivity levels detailed in the cancelled DoD 5200.2-R (PERSEC) then the organization/site must use the OPM Position Designation Tool (PDT) and maintain documentation to reflect the use of the PDT for determination of position sensitivity and background investigation level for each Information Technology (IT) position in the organization.