A few years ago, Michigan government was hit with two computer virus outbreaks in six weeks. Both situations caused system outages, customer complaints, network slowness and more. After we recovered from the second situation, I received shocking news from my forensic team: The security incident was caused by an infected vendor laptop -- again.
Conventional wisdom in government technology circles is that IT vendors, especially big consulting firms, are secure. Most people take for granted that the "experts from out of town" will do no harm as they integrate new technology into enterprise infrastructures. In my experience, this is a bad assumption.
Many of our private-sector colleagues do a good job of putting the right people, processes and technology in place to protect critical systems. But even the best integrators make mistakes. So how do we build the right security provisions into contracts and manage our vendors well?
When I was at the National Security Agency (NSA), many courses were offered on this topic. Staff dedicated entire careers to becoming certified Systems Acquisition Managers who learned the latest vendor-management techniques. No doubt, we need more NSA procurement rigor in state and local governments.
But beyond the art of contractor and vendor management, there are certain topics that require attention that I regularly ran into as a chief information security officer. Here are five areas I recommend addressing as you build Invitations to Bid or negotiate contracts with vendors.
- Staff background checks. While checks are commonplace for criminal justice or tax systems, what about other computers that contain sensitive information? Ensure systems administrators, network engineers or others who have access across multiple programs have been vetted. Even if you require the vendor to run checks, be clear what levels of check are required. In one case, we ran a spot check and found a felony conviction that the contractor didn't know about.
- Build compliant solutions. Do you need to comply with the Payment Card Industry (PCI) standard or other requirements? Be specific about what legislation or certification process must be addressed. Just because a vendor offers a compliant solution doesn't mean that's what you're buying. In Michigan, some vendors asked for a contract change or additional money to make systems PCI-compliant. Often, different options are available.
- Remote connectivity. Many vendors offer "follow the sun" support, which means their staff in other parts of the world will access your systems to troubleshoot and fix problems. Think through this process very carefully. Who has access (see No. 1) and to which systems? Are they using two-factor authentication? (Hopefully yes.) Are you notified when people or processes change? Who's responsible and liable if things go south?
- Involve security staff throughout the life cycle. Do you have competent security staff involved on the project procurement team from the beginning? Building security into all aspects of the Statement of Work and including a member of the security team on the Joint Evaluation Committee will help avoid numerous problems. At least, bring in an expert security adviser when you get down to the final few vendors. Involvement of security officers during the demos or the oral phase of procurement will save time and money later. If vendor site visits are planned for an outsource contract, ensure security expertise is included.
- Use checklists. The National Institute of Standards and Technology offers excellent security checklists at its Computer Security Resource Center. Security requirements should be built into your contract "boilerplate" language where it makes sense.
Ensure contractors comply with the same acceptable use policies and procedures that government staff must meet. For example, what's the policy for vendor laptops entering the enterprise? Are the contractor's portable devices secure? Are laptops checked for viruses before connecting to the network?
A final thought: Gen. George S. Patton once said, "Never tell people how to do things. Tell them what to do and they will surprise you with their ingenuity." Public CIOs must ensure that security is a priority - for contractors too.
Read Dan Lohrmann's column from the December 2008/January 2009 issue of Public CIO, Four Government Security Mistakes to Avoid.