Central Sponsor for Information Assurance
e-Government framework for Information Assurance
Draft 5.1, December 2006
List of abbreviations
ALARM Association of Local Authority Risk Managers
BS Baseline Standard
CA Certification Authority
CAPS CESG Assisted Products Scheme
CC Common Criteria
CCT Mark CSIA Claims Tested Mark
CIFAS Credit Industry Fraud Avoidance System
CIRT Computer Incident Response Team
CLAS CESG Listed Advisor Scheme
CNI Critical National Infrastructure
CO (SPD) Cabinet Office (Security Policy Division)
CRL Certificate Revocation List
CSIA Central Sponsor for Information Assurance
DLA Disability Living Al owance
DoS Denial of Service
DPA Data Protection Act
DTI Department of Trade and Industry
DWP Department for Work and Pensions
EDRMS Electronic Document and Record Management System
EID European Identity Management (Programme)
EIF European Interoperability Framework
ENISA European Network and IS Agency
FCO Foreign and Commonwealth Office
GSi Government Secure Intranet
HMG IS1 HMG Infosec Standard No.1: (Part 1: risk assessment, Part 2: risk treatment)
HMG IS2 HMG Infosec Standard No. 2: risk management and accreditation
HO Home Office
HTTP(s) Hypertext Transfer Protocol (secure)
IA Information Assurance
IAPC Information Assurance Policy Committee
IDABC Interoperable Delivery of European e-Government Services to public Administrators, Businesses and Citizens
ILx Impact Level x
IPR Intel ectual Property Rights
IPS Identity and Passport Service
IS Information System
ISM Interconnection Security Measures
ISO International Organisation for Standardisation
ITSEC IT Security Evaluation and Certification Scheme
MPS Manual of Protective Security
NINO National Insurance Number
NISCC National Infrastructure Security Coordination Centre
NIST (American) National Institute of Standards and Technology
OGC Office of Government Commerce
OGD Other Government Department
PDCA Plan-Do-Check-Act
PIN Personal Identification Number
PKI Public Key Infrastructure
RA Registration Authority
RMADS Risk Management and Accreditation Document Set
SIRO Senior Information Risk Owner
SLA Service Level Agreement
SRO Senior Responsible Owner
SSL Secure Sockets Layer
S/MIME Secure / Multipurpose Internet Mail Extensions
SyOps Security Operating Procedures
TCP/IP Transmission Control Protocol / Internet Protocol
TLS Transport Layer Security
ToE Target of Evaluation
TTP Trusted Third Party
UPS Uninterruptible Power Supply
VbV Verified by Visa
VPN Virtual Private Network
[Note: in the CommentonThis html version most of the 20-odd Tables have been
removed. To see the tables in their original context see
http://www.cabinetoffice.gov.uk/csia/documents/pdf/consultation/ia_framework.pd
f Footnotes simply appear in their original positions in the text]
1 Introduction
1.1 Purpose
1.1.1 This document provides an Information Assurance (IA) policy and guidance
framework for e-Government services,1 setting out a method to assure the
confidentiality, integrity and availability of information assets and to ensure the
correct working of an e-Government service. Special consideration is given to the
identity registration, enrolment and authentication processes which underpin
access control by clients.
1.1.2 Use of this document and application of the policy and guidance that it
contains will :
- enable an appropriate level of IA, supporting reliability and efficiency and
promoting public confidence in e-Government services, with a corresponding
positive impact in the overal public perception of central and local government;
- promote trust between service providers and enable the advantages that
information-sharing and rationalisation of effort wil deliver;
- protect the private information of citizens and organisations, easing the path
to compliance with the Data Protection Act (DPA)2 and other relevant legal
instruments.3
1.2 Scope General
1.2.1 The scope of this document covers the IA aspects of the development,
procurement, provision and maintenance of e-Government services, and of
electronic transactions between government and its clients that are enabled
using these services.
Use of this guidance across government
1.2.2 This document covers e-Government service provision by, or on behalf of:
- central government departments and their supporting agencies;
- non-departmental public sector bodies;
- local authorities4 and other public sector bodies;
1 An e-Government service is a service that is provided by government or agents of government, to
members of the public, delegates or voluntary sector organisations, which is supported by transactions via
an electronic delivery channel such as the internet.2 The DPA and the eight data protection principles that
underpin it are summarised at Section 4.3. 3 See Annex B for a further discussion of relevant legislation. 4
This includes local authorities at a number of levels including county councils, borough and district councils
and other local government organisations such as Local Education Authorities (LEAs).
- security authorities charged with assessing the suitability of offered solutions
for e-Government service provision and accreditation of these solutions for
operational use.
1.2.3 Use of this guidance is not mandatory, but lack of consistency with other e-
Government services would contradict the principles of Transformational
Government, which promotes a shared-services approach to delivery of
coordinated services. Failure to apply the best practice measures set out herein
would weigh heavily against a service provider in the event of an inquiry.
Use by third parties in support of e-Government service provision
1.2.4 This document should be used by those who support e-Government
service provision, such as:
- suppliers and service providers who provide and/or operate e-Government
services or who provide equipment in support of e-Government services;
- bodies responsible for the proper audit and control of public assets and
information;5
- trust service providers such as Registration Authorities (RAs) and providers
of independent regulatory/approvals schemes such as tScheme6 (or equivalent)
who approve trust services for e-Government services;
- external advisors who provide support for the development and accreditation
of e-Government services.7
Offline service provision
1.2.5 Those charged with the development of offline methods of government
service provision to the public (such as telephone and postal applications) may
wish to use this document in an advisory capacity, in conjunction with other
relevant advice and guidance. For example, this document might be useful to
support identification of the required level of assurance for offline processes, and
to help determine an appropriate set of countermeasures.
Clients
1.2.6 It is not general y possible to assure client machines and networks, and
ensuring awareness and best practice by clients of e-Government services is not
straightforward. Clients should be provided with or directed to suitable
guidance on the steps that they should take to protect their machines from online
threats. Basic measures that al home users and organisations should take to
protect their computers are set out at http://www.getsafeonline.org.
footnote 5: This might include, for example, the Electoral Commission as the independent regulatory body responsible
for overseeing some aspects of the accreditation for the Department for Constitutional Affairs (DCA) e-
Voting initiative. 6 Further information on tScheme may be found at http://www.tscheme.org. 7 This includes
CESG Listed Advisor Scheme (CLAS) consultants and other consultants employed to support the
development and/or accreditation of e-Government services, as wel as advisory bodies such as the
Association of Local Area Risk Managers (ALARM) which provide support for development and accreditation
activities.
Internal-facing information systems
1.2.7 Assurance of internal-facing8 government information systems is beyond
the scope of this document. The reader is referred to the policy and guidance set
out within MPS where applicable. Service providers for internal-facing systems
may use this document in addition to MPS as best practice guidance. It should
be noted that under these circumstances MPS takes precedence. Contact details
for those wishing to request a copy of MPS are provided at Section 1.7 of this
document.
1.3 Transitional arrangements
General 1.3.1 The policy and guidance that is set out within this document
represents a significant revision of the previous e-Government security
framework. The transitional arrangements to be adopted are set out below.
New e-Government services
1.3.2 New services are defined here as those services where the relevant
projects or programmes are initiated after the date of publication of Version 6.0 of
this document.9
1.3.3 New e-Government services shal be developed in accordance with the
policy and guidance that is set out within this document, with immediate effect.
Legacy e-Government services
1.3.4 Legacy services are defined here as those services where the relevant
projects or programmes were initiated before the date of publication of Version
6.0 of this document.
1.3.5 For legacy services, the policy and guidance as set out within this
document wil be adopted wherever practicable.
1.3.6 Where service design and specification have already been implemented in
accordance with the September 2002 e-Government security framework
documents, it is not necessary to reassess these services until they are
upgraded or the accreditation environment changes. The current version of the
guidance wil be adopted from that point onwards.
footnote 8: Internal-facing systems will include, for example, information systems that support interdepartmental
interactions and those for use by public-sector workers. 9 Version 6.0 of this document wil be the first issue
version of the document following public consultation.
1.4 Third-party participation Provision of trust services by third parties
1.4.1 Government continues to encourage the provision of trust services by a
variety of bodies, including local authorities and the private sector, and wil make
more use of these services where possible.
1.4.2 Government recognises the continuing importance of the tScheme, and
equivalent initiatives, for accreditation of trust service providers and the need to
maintain a close working relationship to agree detailed standards for trust
services for government transactions.
1.4.3 Any third-party providing trust services support to e-Government
transactions should normal y be approved under a scheme recognised by the UK
Government such as tScheme, or equivalent.
Third-party service delivery
1.4.4 Government makes clear its intention to work in partnership with local
authorities, the voluntary sector, and with third-party delivery channels such as
the Post Office and private sector companies. Where third-party service
providers are conducting transactions on the government's behalf, they wil be
required to provide services to the same standards as government itself would.
Government wil in turn accept transaction data from those delivery channels,
who wil certify that they have carried out the transaction to the agreed standard.
1.5 Ownership and maintenance
1.5.1 This draft of the IA policy and guidance for e-Government services (Draft
5.1) has undergone a significant revision fol owing broad stakeholder
consultation. This document wil be subject to a 3 month public consultation and
revised in line with comments received before being raised to issue Version 6.0.
Thereafter, this document wil be reviewed on an annual basis.
1.6 Glossary
1.6.1 This document includes a detailed glossary, which defines the terms used.
The approach we have taken has been, where possible, to avoid the use of
contentious terms and to align with the terminology set out by related guidance.
Terms that are defined within the glossary are hyperlinked on their first use within
the main body of this document.
1.7 Availability of further support and advice
1.7.1 In the first instance, any queries relating to the policy and guidance
provided within this document should be directed to the CSIA at:
- CSIA, Cabinet Office, 22 Whitehal , London. SW1A 2WH. Email:
csia@cabinet-office.x.gsi.gov.uk
1.7.2 Documentation requests for MPS and other supporting documentation,
should be addressed to the Cabinet Office (Security Policy Division) (CO (SPD))
at:
- CO (SPD), Cabinet Office, 22 Whitehal , London. SW1A 2WH. Email:
security.division@cabinet-office.x.gsi.gov.uk 1.7.3 Queries and comments on
HMG IS1, HMG IS2 and other CESG guidance should be addressed to CESG at:
<li>CESG Customer Support Office, Hubble Road, Cheltenham, GL51 0EX.
Email: enquiries@cesg.gsi.gov.uk 1.7.4 A list of CESG Listed Advisor Scheme
(CLAS) consultants is maintained on the CESG web-site,
http://www.cesg.gov.uk/site/clas/index.cfm. 1.7.5 Further information on the
Association of Local Authority Risk Managers (ALARM) may be obtained from
their web site, http://www.alarm-uk.com.
1.8 Document overview
1.8.1 The layout of this document is as fol ows:
- Section 2 provides an overview of how to use this document and sets out the
five-step methodology that has been adopted;
- Section 3 describes the overal approach to risk management and
accreditation that should be adopted by those responsible for IA aspects of e-
Government service provision, and how the concepts of risk ownership, IA policy,
service delivery and compliance checking apply to e-Government services;
- Section 4 il ustrates the service provision environment and context for e-
Government services, setting out the boundaries of the service provision
environment, the requirements to protect the service, attack groups and
compromise paths, and data protection obligations;
- Sections 5-10 discuss each of the service characteristics as defined by this
guidance, covering identity registration, enrolment, authentication, confidentiality,
integrity and availability; considerations for each of these include estimation of
impact levels, the general process, threats and baseline countermeasures that
are required and specific countermeasures for a particular level of required
assurance;
- Section 11 provides worked examples demonstrating the application of the
policy and guidance that is set out within this document;
- Annex A provides a comprehensive glossary defining the terms used within
this document; the approach taken in this guidance has been, where possible, to
avoid the use of contentious terms and to align with the terminology set out by
related guidance;
- Annex B contains information on other relevant policy and guidance;
- Annex C is a reference to the definitions of the four service provision levels
as defined by earlier versions of the e-Government security framework
documentation;
- Annex D sets out the HMG Impact Table definitions; these are to be used to
estimate the impact levels for e-Government service characteristics;
- Annex E presents some examples of acceptable remote and online evidence
for the identity registration of an individual.
2 How to use this document
2.1 Introduction General
2.1.1 This document forms part of the overal risk management process to be
adopted throughout the project lifecycle of an e-Government service.
2.1.2 This section introduces the method to be employed for risk assessment and
risk treatment, and demonstrates how this method should be applied. The
context for the guidance and relevant risk management concepts are also
introduced, and the relationship between this document and other government
guidance on risk management and IA is discussed.
2.1.3 The overal approach to risk management and accreditation is summarised
and discussed at Section 3 of this document.
Context
2.1.4 e-Government service providers have a requirement to ensure that:
- where necessary, a client is who they claim to be, they are eligible for a
service they receive, and they are entitled to transact with e-Government
services either on their own behalf or on behalf of another;
- the confidentiality of the information stored and handled by e-Government
services, and any information exchanged between e-Government services, is
appropriately protected;
- the integrity of the information stored and handled by e-Government services,
and the ability to make binding commitments based on this information, is
appropriately protected;10
- e-Government services are available to the communities that they serve, and
the service provision domain is protected against electronic attack (both
malicious and non-malicious) and non-malicious failure.
Relationship with other IA policy and guidance
Manual of Protective Security
2.1.5 This document forms part of the wider documentation set that supports the
Manual of Protective Security (MPS) and has the status of a stand-alone
supplement to the MPS.
2.1.6 The policy and guidance that is set out within this document fol ows the risk
management approach prescribed by HMG Infosec Standard Number 2 (HMG
IS2).11 This approach to risk management is broadly aligned with ISO and OGC
guidance, and adherence wil ease the route to ISO 27001 compliance.
2.1.7 HMG Infosec Standard Number 1 (HMG IS1)12,13,14 provides a risk
assessment method that focuses on support for information in the high
assurance domain.15 The HMG IS1 method, however, is not designed to support
e-Government service provision:
- HMG IS1 provides inadequate resolution across the relatively low assurance
requirements of most e-Government services;16
- the range of likely attack groups wil tend to be more limited;17
- HMG IS1 is not client-centric and does not consider the management of client
identities or obligations to protect the information of clients under the DPA, the
Human Rights Act, and other legal instruments; a related issue is the protection
of clients' information and service provision as a whole in an environment where
client machines wil be protected to a range of different levels. 2.1.8 The IA policy
and guidance provided herein is designed to support the provision of e-
Government services and protection of the information assets that are managed
by these services. There remains, however, a particular requirement to apply
HMG IS1 in addition to this guidance in the fol owing circumstances:
- to protect services with a broader range of attack groups and/or IA
requirements that are above and beyond those considered here;
- where relevant, for the protection of back-end systems.
Footnotes 11 HMG Infosec Standard Number 2: risk management and accreditation of information systems,
dated July 2005. This document may be downloaded from the NISCC web-site, http://www.niscc.gov.uk. 12
HMG Infosec Standard Number 1 Part 1 (Risk Assessment), Draft 1.0 of Issue 3.0, June 2006, NOT
PROTECTIVELY MARKED. 13 HMG Infosec Standard Number 1 Part 2 (Risk Treatment), Draft 1.0 of Issue
3.0, June 2006, NOT PROTECTIVELY MARKED. 14 HMG IS1 is currently undergoing a comprehensive
review. The new draft documentation replaces the traditional impact-based central government approach to
IA with a threat-based approach. 15 Supporting RESTRICTED through to TOP-SECRET information. 16 Ie
requirements to support the confidentiality of information assets will typically be at-or-below RESTRICTED,
with similar requirements for the integrity and availability of services and information assets 17 For example,
with the exception of some central government services and elements of the CNI, many e-Government
services are unlikely to be particular targets for terrorists or foreign intel igence services.
CSIA identity risk management tool
2.1.9 A CSIA e-Government identity risk management tool is under development,
to support a standardised approach to identity risk management by supporting
the identification of impact levels for registration and authentication,18 and the
countermeasures to be applied. Enquiries relating to this tool should be directed
to CSIA via the contact provided at Section 1.7.
Infosec manuals and memoranda
2.1.10 In addition to HMG IS2, e-Government services with increased IA
requirements may need to implement HMG IS1 directly, along with some of the
technical countermeasures that are set out within the Infosec Manuals and
Memoranda. National Infrastructure Security Coordination Centre guidance
2.1.11 A range of guidance on the implementation of technical countermeasures
to address specific risks is provided by the National Infrastructure Security
Coordination Centre (NISCC), and can be found on the NISCC website,
http://www.niscc.gov.uk. This guidance is particularly aimed at protecting
elements of the Critical National Infrastructure (CNI), but much of the guidance
provided represents industry-wide best practice.
2.2 Risk assessment method
General
2.2.1 Risk assessment should be conducted at an initial stage in the
development lifecycle for e-Government services and developed to an increasing
level of detail as service development progresses. Where possible, the
Accreditor should be involved early on and throughout the service lifecycle; early
feedback wil help to inform the development of the service, mitigating risks and
potential y reducing development costs.
2.2.2 The e-Government IA risk assessment method consists of the fol owing
steps as il ustrated at Figure 1:
- 1. define the service in business terms;
- 2. determine impact levels for each service characteristic; this might require
redefinition of some elements of the service;19
- 3. apply standard minimum countermeasures;
- 4. apply service-specific countermeasures; this might require redefinition of
some elements of the service;
20 18 The tool also includes some discussion of enrolment and proof of status. 19 For example, to reduce the
value of some of the impact levels. 20 For example, introducing physical, procedural or personnel measures
in place of some countermeasures.
- 5. agree and document risk management decisions; this might impact on the
required countermeasures.
[Figure 1 deleted]
2.2.3 The risk assessment method is described below. Section 11 provides
worked examples to demonstrate how this method should be applied.
STEP 1: define the service
2.2.4 In order to determine IA risks and requirements, there is a requirement to
first define the e-Government service in business terms. This might require
consideration of, for example:
- the client requirements from the service and the range of functions that wil
need to be performed in support of this service;
- the service requirements from the client. This might, for example, include the
need to establish a client's identity, and requirements for non-repudiation,
evidence of receipt and trusted commitment services;
- the individuals that wil be responsible for the service and its information
assets, including the Senior Responsible Owner (SRO), the Senior Information
Risk Owner (SIRO) and other responsible individuals;
21 21 Risk ownership is discussed further at Section 3.2.
- definition of the service provision environment, considering: - the information
assets in the system; - the assumptions that can be made about the service; -
the boundaries of the service; - the external connections and other third-party
interaction required; this includes consideration of information exchange
requirements, pre-requisites for each connection, balance-of-responsibility for
management, etc; - the likely attack groups and what compromise paths they
might exploit; - the transactions that wil support the col ection, processing,
exchange, storage and disposal of information; - the delivery mechanisms
required to support different elements of the service (eg internet, telephone, text,
post, etc) and the access mechanisms that wil be employed (eg government
gateway); - service delivery and the potential for outsourcing elements of service
provision.
2.2.5 A generic service provision model, likely attack groups and potential
compromise paths are discussed at Section 4 of this document. STEP 2:
determine impact levels for each service characteristic
2.2.6 Six service characteristics are defined for e-Government services, covering
confidentiality, integrity, availability, identity registration, enrolment and client
authentication.22
[Table 1 deleted]
2.2.7 For each transaction to be conducted, an impact level should be assigned
for each of the six service characteristics defined above. Each service
characteristic wil , in general, attract a different impact level.
2.2.8 The distinction between information assets and transactions must be noted.
Identity registration, enrolment and authentication are mechanisms which support
the transactions by which information assets are managed, rather than the
information assets themselves. As such, although each transaction wil attract an
impact level for each service characteristic as set out at Table 1, information
assets themselves wil only attract impact levels for confidentiality, integrity and
availability.
2.2.9 Considerations during the assignment of impact levels are as fol ows:
- four impact levels are defined, ranging from Impact Level 0 (IL0) to Impact
Level 3 (IL3); these impact levels are defined by the HMG Impact Table, which is
reproduced in part at Annex D of this document and provides a means by which
to value24 the transactions and information assets that support a service;
- some transactions or information assets wil attract impact levels in excess of
IL3 for one or more service characteristics, so that the ful HMG Impact Table25
must be consulted; in these cases, HMG IS1 should be applied to
determine appropriate countermeasures in addition to those in this document;
- al ocation of impact levels wil require consideration of al direct and indirect
consequences laid out in the definition of the levels, al ocating the highest of
these to the transaction; it is unlikely that al of the definitions in the Impact Table
wil be relevant for each service characteristic;
footnote 23 The use of the term "enrolment" as defined here should not be confused with the HO / IPS definition,
which relates specifical y to biometrics. 24 Readers should note that value, as defined here, does not
necessarily refer to monetary value. 25 This is to be produced by CSIA as a stand-alone document.
2.2.10 After assigning impact levels for a particular transaction within a service,
the service provider wil need to determine how to deliver the functionality of the
service. It might be most appropriate to assign a set of impact levels for each
transaction, and to register, enrol and/or authenticate clients at different levels of
assurance depending on the range of transactions that they wish to perform.
Alternatively, it might be most convenient to define a single set of impact levels
for all transactions within the entire service.
STEP 3: apply standard minimum countermeasures
2.2.11 This document defines a standard set of minimum countermeasures to be
implemented by al e-Government services in support of each of registration,
enrolment, authentication, confidentiality, integrity and availability. These
countermeasures are set out in the relevant sections of the document (Section 6
to Section 10 respectively).
2.2.12 Service providers should also implement the standard minimum
countermeasures specified by HMG IS1, which include:
- undertaking risk management and accreditation in accordance with HMG IS2,
and set out in part at Section 3 of this document;
- producing system operating procedures;
- producing a patching policy (to define how and when operating system
service packs and security patches wil be applied);
- using anti-virus software;
- implementing MPS for protectively marked material;
- all e-Government services wishing to comply with the ISO 27000 series
should implement the controls listed in the ISO 17799 Code of Practice.
2.2.13 In addition, government has a responsibility to provide support for clients,
which, as a minimum should include:
- directing clients to suitable guidance on the steps that they should take to
protect their computer from online threats and of the risks of using unsecured
machines; basic measures that al home users and organisations should take to
protect their computers are set out at http://www.getsafeonline.org;
- informing clients of their general responsibilities to protect any logon
credentials that they are issued with and of the potential implications of
disclosure;
- informing clients of any specific instructions relating to the issue of
credentials (especial y tokens or other devices); these may, for example, be
accountable and/or have special handling instructions which must be notified to
the client.
STEP 4: apply transaction-specific countermeasures
2.2.14 This document defines the level of countermeasures that are required,26
depending on the identified impacts for each of registration, enrolment,
authentication, confidentiality, integrity and availability. Some of these are
determined by the identified impact level and others wil depend on specific
requirements of the transaction (eg in support of a requirement for non-
repudiation, evidence of receipt or trusted commitment services).
2.2.15 The choice of countermeasures must be considered in terms of risk to the
service as a whole, cost of implementation, practicality and overal business
benefit. The SIRO may choose not to implement some transaction-specific
countermeasures where it is determined that these cannot be adequately
supported but there is an overwhelming business need for the service.
2.2.16 In these cases, the countermeasures that are not met and the reasoning
behind this must be clearly documented in the Risk Management and
Accreditation Document Set (RMADS) for the service.27 Residual risks should be
mitigated, where possible, through the application of appropriate procedural,
physical and personnel measures. Important factors in determining the
appropriate risk level include the the residual risk that the risk owner is prepared
to accept, and prerequisite requirements for any envisaged onward connections.
Support and advice from technical experts is essential to properly inform risk-
balance decisions.
STEP 5: agree, document and implement risk management decisions
2.2.17 Al decisions related to risk assessment and risk management must be
clearly documented in a RMADS. This should include:
- an asset register detailing information assets and their impact levels;
- a comprehensive list of transactions and their impact levels;
- a prioritised risk register, supported by a risk treatment plan;
- details of through-life management for IA and the IA review process;
- details of the acceptance processes for clients and government users;
- a map of external connections and information-flow requirements;
- a list of countermeasures that have been implemented and any exceptions
made;
- procedures to ensure secure decommissioning and transfer or disposal of
information assets.
26 Details of the precise countermeasures to be applied must be determined on a service-by-service basis at
an appropriate level of detail, as determined by this guidance. 27 The level of detail required within the
RMADS wil depend on the impact of the service. For example, for an e-Government service whose service
characteristics are mostly IL1, an outline RMADS would general y be sufficient. However, for an e-
Government service whose service characteristics are mostly IL3, a greater level of detail would general y
be required to support the implementation and management of IA for the service.
2.2.18 Prior to rol -out of an e-Government service, the service provider must
consider how the required level of IA wil be delivered. This might include
developing a clearly documented policy on what compromises and losses are
and are not acceptable (these might not necessarily be limited to financial
losses), how to monitor such losses and what exception-handling procedures
should be used to respond to compromise, minimise loss, and improve the
service. This may include the development and implementation of a liability
model. Considerations might include, for example, ensuring that third-parties are
subject to contractual bindings and are incentivised through transferral or sharing
of risk where possible. Measures for audit and accounting, and any other
activities that may be reasonably employed to monitor, record and analyse
incidences of compromise or potential compromise must be put into place.
2.2.19 Measures to protect the service and its information assets must be
supported by continual regular review of IA procedures and appropriate
mechanisms for exceptional review of IA procedures in the event of urgent
unforeseen circumstances. As such, the RMADS should be treated as a "living"
document and wil require regular scheduled reviews and change-management.
Changes to the RMADS should be agreed and endorsed by al stakeholders and
should be reflected by training as appropriate.
3 Risk management and accreditation
3.1 General
3.1.1 This section sets out the approach to risk management and accreditation to
be adopted in support of e-Government service provision.
3.1.2 The HMG IS228 approach to risk management has been adopted. This
approach is broadly aligned with ISO and OGC guidance on risk management.
Adherence wil help an organisation to demonstrate compliance with the ISO
27000 series of documents, and ease the route to ISO 27001 compliance.
3.1.3 It is anticipated that this document wil be used in conjunction with HMG
IS2. As such, we have not repeated the guidance contained in HMG IS2, but
concentrate on how to tailor this approach to support e-Government service
delivery.
3.1.4 The overal risk management approach is set out at Figure 2. This
approach is built around four main topics covering risk ownership, IA policy,
service delivery and compliance checking.
[Fig 2 deleted]
footnote 28 HMG Infosec Standard Number 2: risk management and accreditation of information systems, dated July
2005. This document may be downloaded from the NISCC web-site, http://www.niscc.gov.uk.
3.2 Risk ownership General
3.2.1 Overal responsibility for the protection of information assets that are
supported by an e-Government service lies with the SIRO for that service. This
does not diminish the individual responsibilities of users of a service and those
responsible for managing that service. A number of key roles are set out below.
Senior Information Risk Owner
3.2.2 The SIRO is an individual identified within each department as being
responsible for information risks and for influencing the board in managing these
risks properly.
3.2.3 For e-Government services that are delivered by or on behalf of central
government organisations, the SIRO wil be a senior business manager, who
works in conjunction with the service provider (who may or may not belong to the
same organisation) and the Accreditor to select, implement and assure security
measures for the service. This model represents best practice for those
developing e-Government services.
Accreditor
3.2.4 An accreditor is the individual responsible for conducting the formal
assessment of an information system or a set of capabilities and for advising the
SIRO on the risks to information assets.
3.2.5 Responsibility for accreditation of services within a department rests with
the departmental accreditor. Responsibility for accrediting services which span
several departments rests with the pan-government accreditor.29
3.2.6 The primary responsibility of the SIRO is to deliver a service which has an
appropriate level of capability to support clients' needs, whereas the Accreditor
has to be aware of the potential IA pitfal s which a service might encounter and
ensure that these have been addressed to an appropriate level of assurance.
Maintaining the correct balance of the tension that tends to result between the
SIRO and the Accreditor is essential to obtain the optimum risk balance for the
service.
Service provider
3.2.7 A service provider is an organisation responsible for the provision of a
specific e-Government service. The service provider might merely operate the
service using its own or government-owned equipment, or it might design and
develop the service.
footnote 29 The role of the pan-government accreditor is due for review over the next year.
3.2.8 The service provider must ensure that the service and relevant systems are
compliant with the e-government security framework, as required by the SIRO
and in conjunction with the Accreditor.
Government users
3.2.9 A government user in this context denotes a person or process that
interacts with an e-Government service (in any capacity) from within the e-
Government service provision boundary; this includes third parties involved in the
provision of e-Government services.
3.2.10 Appropriate measures must be put into place (training, awareness, etc) to
ensure that government users are familiar with corporate security and IA policies,
and to ensure that they have read and understood the security policies and
guidance specific to the service.
Clients
3.2.11 The term client is used here to denote a person or organisation, a
delegate of a person or organisation, or an element of another service seeking to
carry out a transaction using an e-Government service.
3.2.12 Clients are responsible for protecting information on their own computers
and networks, and for their end of any transactions undertaken with government.
Ensuring awareness and best practice by clients of e-Government services is not
straightforward. Different clients wil use a range of different hardware and
software platforms, with a wide range of different (and evolving) configurations. In
addition, some client systems may have been compromised by malicious
individuals, so that there is a requirement for appropriate measures to be in place
to protect the e-Government service and to support users in protecting their own
systems.
3.2.13 It may be necessary to require clients to instal standard commercial
security products as a pre-requisite to accessing some e-Government services.30
However, any requirement for a client to instal custom software to access e-
Government services should be avoided.
3.2.14 Appropriate measures must be in place within the e-Government service
provision boundary to protect a client's information on their behalf. It should be
noted, however, that a client might be prepared to accept a higher level of
residual risk than the service provider regarding their information, or may have a
different assessment of the impact that compromise of that information might
have. This should not prevent the service provider from providing clients with
information that is held about them. For example, assignment of Confidentiality
IL3 to a client's medical records should not prevent the e-Government service
provider from enabling access to this information (even if this requires the use of
out-of-band methods).
footnote 30 For example, ensuring that the client upgrades to a web browser with an up-to-date version of the Secure
Sockets Layer (SSL) protocol prior to use of the service.
Delegates
3.2.15 A delegate (also referred to as a proxy) is an intermediary that has been
authorised to conduct a specified set or range of transactions on behalf of an e-
Government client. This might include, for example, an accountant or other
professional acting on behalf of a specified person or organisation, a legal
guardian, or a person acting under a power of attorney on behalf of a relative or
patient.
3.2.16 In some cases a delegate would be entitled to perform any transaction
offered by a service for the client on whose behalf they act. More general y, a
delegate would be authorised to perform some wel -defined subset of the
activities that the client they represent is able to perform (for example, an
accountant might be authorised to complete a client's tax returns, but might not
be authorised to change that client's address details).
3.3 IA policy
General
3.3.1 Responsibility for the management and implementation of an organisation's
security and IA specific policies should be assigned to specific personnel, with
the appropriate level of knowledge and expertise.
3.3.2 The IA policy relating to an e-Government service should be documented in
an RMADS,31 as set out in HMG IS2, covering:
- how IA supports the business requirements;
- physical, procedural and personnel measures;
- exception-handling procedures;
- advice within the organisation to al those involved in IA risk management;
- IA awareness and training;
<li>IA incident reporting and recovery operations;
- compliance with appropriate standards, policies and laws.
footnote 31 The level of detail required within the RMADS wil depend on the impact of the service. For example, for
an e-Government service whose service characteristics are mostly IL1, an outline RMADS would general y
be sufficient. However, for an e-Government service whose service characteristics are mostly IL3, a greater
level of detail would general y be required to support the implementation and management of IA for the
service.
Risk assessment and treatment
3.3.3 Having fol owed the method set out within this document for assessing
risks, there are a number of options available when considering how to manage
those risks. The IA risk management process adopted involves determining
whether to:
- mitigate, by introducing countermeasures to reduce the likelihood and
impact of the risk
- avoid, by considering alternative means by which the business objective is to
be achieved or by considering the business impact of reducing the functionality of
the service or not providing the service;
- transfer, by considering methods for transferring responsibility;32
- accept a higher level of risk to the service and to the information assets that
it supports in cases where there is a demonstrable overwhelming business
benefit associated with the provision of the service.
Security management
3.3.4 Appropriate physical and procedural measures must be in place as
elements of a multi-layer approach to IA. Detailed guidance on the
implementation of physical and procedural measures is beyond the scope of this
document. ISO 17799:2005 provides a discussion on the implementation of
physical and procedural measures to ensure and maintain confidentiality. e-
Government service providers with a requirement to handle protectively marked
information wil need to refer to MPS.
3.3.5 Physical and procedural measures should include:
- clearing government users to an appropriate level; government users
supporting services with Confidentiality IL3 must be cleared to at least BS,33 and
it is strongly recommended that government users with access to Integrity IL3
and Availability IL3 services are cleared to an equivalent level;34
- setting clearly-defined physical security perimeters and assessing the
strength of these perimeters;
- putting appropriate measures into place to manage access points, putting
appropriate physical authentication mechanisms in place to ensure that the
strength of these are commensurate with the perimeter they support and putting
appropriate processes into place to audit access;
- securing offices, rooms and facilities (subject to health & safety regulations),
supported by appropriate procedures and training for staff (for example to ensure
that sensitive areas are locked out of office hours, that unauthorised staff are
escorted at al times, that maintenance staff are not al owed unconstrained
access to sensitive areas, etc);
- ensuring the security of equipment (including mobile equipment) against loss,
damage, theft or other compromise and making sure that appropriate measures
are in place to support secure decommissioning of physical assets on which
information assets or other sensitive material is stored.
32 This option must be treated with caution. Even if responsibility for limiting risk is transferred to outside the
organisation, the risk wil stil rest wherever the business impacts are actual y felt. 33 SC clearance as a
minimum would be preferable for central government users with access to sensitive information. 34 It may
also be prudent to ensure clearance of government users who support lower-impact services, especial y
those with Confidentiality IL2, Integrity IL2 and/or Availability IL2.
3.4 Service delivery Project and asset management
3.4.1 IA and risk management is a through-life process, as il ustrated within the
OGC Gateway model at Figure 3. An outline RMADS is developed during early
planning and feasibility studies, developed to additional levels of detail up until
the delivery of the service.
3.4.2 Risk management during the in-service lifetime is a continual process of
review, revision, monitoring and improvement. Risks should be reassessed and
the RMADS reviewed on a continual basis to support changes in the service
environment,35 threat environment,36 major upgrades, deployments, etc.
footnote 35: A change in the service environment might involve the introduction of a disruptive new technology, or a
step change in the evolution of an existing technology, which introduces new opportunities for service
provision and associated threats. 36 A change in the threat environment might involve the identification of a
newly-identified threat actor or vulnerability. A step change in the service environment would also be likely to
present a change in the threat environment.
[Fig. 3 deleted]
Interaction with third-parties
3.4.3 Outsourcing and use of commercial technologies can bring significant
benefits to service providers, including reduced time-to-market and exploitation of
new technologies, increased agility and flexibility and the reduction in overheads
such as development overheads.
3.4.4 Outsourcing contracts, or elements of contracts, for the development,
procurement, provision and maintenance of services can be complex. This is
particularly true for large public-sector projects, as witnessed by a number of
recent high-profile security failures. Outsourcing raises a range of issues for IA
which must be mitigated through the development of suitable procedures
supported by appropriate contractual mechanisms.
3.4.5 Basic considerations for IA of outsourced contracts cover the procedures
that must be put into place for risk assessment and security requirements
capture, supporting measures for security reporting and assurance by the
supplier and establishing right of audit (which may require negotiating IPR
issues).
3.4.6 NISCC good practice guidance on outsourcing37 provides an outline
discussion of these issues.
3.5 Compliance Accreditation
3.5.1 Accreditation is the formal assessment of an information system or a set of
capabilities against the IA requirements of the information assets of that
information system or capability set. The accreditation process provides evidence
that an appropriate set of measures are in place to ensure an acceptable level of
risk for the confidentiality, integrity and availability of information assets that are
stored and handled within the accreditation boundary.
3.5.2 The impact levels for a compromise of the confidentiality, integrity and
availability of information assets are determined by the SIRO. For e-Government
services, impact levels for a compromise of the identity registration, enrolment
and authentication processes that support the service must also be determined.
The impact levels should be determined in consultation with the Accreditor,
supported by a ful risk assessment to set out the business impacts of
compromise. Important factors in determining the countermeasures that must be
in place and the level of residual risk to accept for information assets include the
residual risk that the risk owner is prepared to accept, and any prerequisite
requirements for envisaged onward connections.
3.5.3 Accreditor involvement is required at al stages of the project lifecycle. The
Accreditor should be involved to support the decision to proceed through each of
the gateways from GatewayTM 1 through GatewayTM 5. Accreditor involvement as
early as GatewayTM 0, and throughout the development process, is strongly
encouraged to enable early identification and mitigation of risks to the
confidentiality, integrity and availability of information assets.
3.5.4 Where formal accreditation is required, this is an essential prerequisite to
the fol owing activities, supported by evaluation and testing as appropriate:
- use of pilots handling live data or live information feeds;
- approval-to-operate for a system or set of capabilities;
- changes to capabilities or supporting infrastructure, or to their use;38
- discovery of new vulnerabilities, or changes to known vulnerabilities or likely
threat scenarios.
37 Outsourcing good practice guide: security governance framework for IT managed service provision, dated
2 August 2006. This document may be downloaded from the NISCC web-site, http://www.niscc.gov.uk.
Evaluation / testing
3.5.5 It is expected that government wil make use of normal commercial
technologies and techniques wherever possible, subject to compatibility with
these guidelines, and ensure that services are accessible from as wide a range
of client platforms as possible.
3.5.6 Use of IT security products and services that have been formal y certified
under the CSIA Claims Tested (CCT) Mark scheme, the CESG Assisted
Products Scheme (CAPS) or other assurance schemes such as the UK
Information Technology Security Evaluation and Certification (ITSEC) scheme
and Common Criteria (CC) is encouraged, to support trust in e-Government
service delivery.
3.5.7 Table 2 sets out government best practice for assuring the confidentiality of
information systems. The focus of this table is on protecting the confidentiality of
information assets, but several of the measures suggested wil also support the
integrity of information assets and the availability of the service:39
- at IL0, commercial best practice is recommended, supported by an internal
audit to test compliance; baseline countermeasures to be applied in support of e-
Government services are set out at Sections 5-10 of this document;
- at IL1, product, service and system assurance equivalent to EAL 1 should be
used, supported by approval by the Accreditor and an ISO 27001 audit where
relevant;
- at IL2, product, service and system assurance equivalent to EAL 1/2 should
be used, supported by approval by the Accreditor and an ISO 27001 audit where
relevant;
- at IL3, product assurance to CC 2/3, service assurance under the Future
Assurance Model and use of Low Tailored Assurance for system assurance
should be used; a CHECK audit of the service may be required
in some cases and Confidentiality IL3 services should be subject to formal
accreditation (and an ISO 27001 audit where relevant). [Table 2 deleted]
38 Routine activities such as antivirus updates or security and bug patches are not expected to fall into this
category, and should be documented within the supporting documentation for accreditation. However, a
decision to reaccredit might be required fol owing a major patch (Windows XP SP2 is a good example of
such a patch). 39 Calculated at the high-water mark of the impact levels attracted to confidentiality, integrity
and availability. For example, a service attracting Confidentiality IL0, Integrity IL0 and Availability IL1 should
consider the best-practice process at IL1.
4 Service provision environment
4.1 General
4.1.1 This section il ustrates a typical service provision environment and context
for e-Government services. This section considers the boundaries of the service
provision environment, the requirements to protect the service, attack groups and
compromise paths, and data protection obligations.
4.2 Service provision environment Service provision model
4.2.1 Figure 4 presents a generic model for the e-Government service provision
environment. The e-Government service wil typical y manage a combination of
information that is electronical y accessible by clients, and information that is
accessible to government users only. In addition, an intermediary such as the
Government Gateway might be used to manage interactions between the e-
Government service domain and the client. E-Government service
[Figure 4 deleted]
4.2.2 The "client information space" in the figure refers to information that is
made available to clients. In practice, this information may be subdivided to
represent information that is available electronical y to clients with different levels
of authorisation40 or entitlement.41
4.2.3 The "government user information space" in the figure refers to information
that is made available electronical y to government users. This may or may not
include some or al client information. The information within this space might
attract a higher set of impact levels and require a greater level of protection than
the information that is made available to clients. In practice, there may be a
number of such information spaces, representing information that is available to
government users with different roles.
4.2.4 It is envisaged that the Government Gateway wil be used by many e-
Government services as an intermediary between the e-Government service
domain and the client, enabling consistency in interactions with clients and
reducing the service development overhead. It is expected that the Government
Gateway wil be responsible for the management and protection of some or al of
the identity registration, enrolment and authentication details that are required to
support some e-Government services.
4.2.5 There may potential y be requirements for an e-Government service to
interact with trusted third parties via a number of channels, including:
- direct interaction between e-Government services where system
architectures al ow, for example to support the exchange of sensitive information
about the client (subject to DPA constraints) or to verify client identity or
entitlement;
- indirect communication via "portal" services such as the Government
Gateway or government networks such as the GSi, particularly in support of pan-
departmental client transactions such as promulgating a client's personal details;
- information exchange with clients and trusted third parties across the internet,
for example tunnel ing using a Virtual Private Network (VPN) or via web hosting.
4.2.6 Those elements of the e-Government service environment that are
managed by elements of government are encompassed within the service
provision boundary. The accreditation boundary encloses a subset of the service
provision boundary.
footnote 40 For example, an e-Government service that provides read-only access to information by clients might be
judged to have Integrity IL0. If read-write access to the same information is judged to have a greater impact
level for integrity, then clients may be required to undergo a more rigorous identity registration process to
support this additional capability. 41 A client that is registered for a service might be able to perform a range
of functions. That client might allow a delegate to perform a wel -defined subset of those functions. For
example, a client who is registered for online tax returns might be able to submit their annual tax return or
change their address details. An accountant who is delegated to act on their behalf might only be permitted
to submit tax returns.
Protecting the service
4.2.7 Considering Figure 4, there is a requirement to protect:
- information in transit from clients to the e-Government service and
vice-versa; this requirement is not limited to information transferred from the
client machine via online channels, but also includes information transmitted via
offline (eg post) or other electronic channels (eg SMS message) that might
impact on the e-Government service;
- the e-Government service and other elements within the service
provision boundary such as the Government Gateway and any connected
machines and other infrastructure; this includes a requirement for secure erasure
and disposal of information that has been stored and handled by or on behalf of
the e-Government service when it is no longer required;
- information exchange, including information exchanged between e-
Government services and information in transit between an e-Government
service and a Trusted Third Party (TTP) such as an Other Government
Department (OGD) or RA; this includes a requirement to ensure that client
consent is obtained before promulgating information for use beyond the purpose
for which it was supplied. 4.2.8 Service providers also have a duty of care to aid
clients in the protection of their electronic identity and of information that relates
to the e-Government service that is stored on their machines or provided using
these machines.
Attack groups
4.2.9 General types of attack group to be considered include, for example:
- individual fraudsters and organised criminal groups who might, for
example create false identities, misappropriate genuine real-world identities or
simply misuse their own real-world identity in order to try to claim benefits for
which they are not entitled
- journalists, private investigators, inquisitive individuals and others who
might, for example, be in search of a news story, be gathering evidence to be
used against a client or simply be curious to know some private detail about their
neighbour;
- commercial competitors of e-Government clients who might, for example,
seek to gain a competitive advantage by eliciting private information such as
financial details;
- hackers who might, for example, be testing their abilities, trying to impress
their peer group, cause mischief, or be in the pay of a more malicious threat
actor; 4.2.10 Other non-standard attack groups might also need to be considered
by e-Government service providers, particularly for those services relating to
elements of the CNI:
- foreign intelligence services with political, commercial or other motives;
- terrorists seeking to misuse or disrupt government resources. 4.2.11 Service
providers wil also need to consider attack groups acting from within the e-
Government service provision boundary, such as government whistleblowers and
other disgruntled government employees, employees of service providers who
may not have been subject to the same vetting procedures as government
employees, maintenance staff and cleaners, etc. These attack groups are
considered elsewhere and are beyond the scope of this guidance.
Compromise paths
4.2.12 General compromise paths to be considered might include, for example:
- access control attacks, such as leveraging improperly assigned or retained
user privileges, or attacks on credentials and supporting information through
theft, cracking, guessing, forging, cloning, interception, observation, social
engineering, etc.
- network attacks which might, for example, employ viruses, worms or
Trojans, network or transport layer attacks, application layer attacks such as
browser or operating system vulnerabilities, denial of service attacks, etc
- passive interception attacks such as interception of unencrypted network
traffic;
- accidental compromise by authorised users, such as user error in
entering, amending, moving, exchanging or deleting information;
- deliberate compromise by authorised users such as deletion, falsification
or misappropriation of information.
4.3 Data protection
Data protection principles
4.3.1 Data control ers must comply with the eight data protection principles under
the DPA. These may be summarised as requiring that personal data must be:
- 1. processed fairly and lawful y;
- 2. obtained and processed only for one or more specified and lawful
purposes, and shal not be further processed in any manner incompatible with
that purpose or those purposes;
- 3. adequate, relevant and not excessive;
- 4. accurate and, where necessary, kept up to date;
- 5. held for no longer than is necessary for the required purpose or purposes;
- 6. processed in accordance with the rights of data subjects;
<li>7. supported by appropriate technical and organisational measures against
the unauthorised or unlawful processing of personal data and against accidental
loss, destruction or damage;
- 8. not transferred to a country or territory outside the European Economic
Area, unless that country or territory ensures an adequate level of protection for
the rights and freedoms of data subject in relation to the processing of personal
data.
Protection of e-Government services
4.3.2 A number of specific data protection points arise for the mutual obligations
of government and those it deals with, relating to the use of e-Government
services. In particular:
- service provision should operate on a principle of maximum anonymity
consistent with necessary functionality;
- it should be clear to the client why information (for example identity
registration and enrolment information) is being requested;
- information that has been provided by a client should not be used for
secondary purposes without first obtaining prior and informed consent from the
client;42
- personal or commercial y sensitive information must be released only against
reliably verified authority;
- where there is a requirement for information exchange, only that information
which is relevant should be passed on;43
- it may be necessary to retain information, such as identity registration
information, for a reasonable period for reasons of accountability, audit, etc;
these requirements must be balanced against the requirements of the DPA;
- services and benefits should be provided only to those entitled to receive
them;
- the criteria for access and entitlement to particular services should be
communicated clearly to clients;
- clients must be protected, where possible, against misuse of their authority;
- government organisations, and those that they deal with, must be bound by
declarations they have made and instructions they have given;
- adequate procedures must be in place to prevent unauthorised disclosure of
personal data; this requires an appropriate level of assurance for identity
registration, enrolment and authentication supported by measures to protect
information stores and information in transit.
footnote 42 There may also be a requirement In exceptional circumstances to release information to government
agents without informing the client, for example in support of police activities, or in the interests of national
security. 43 For example, where a trust service provider registers a client on behalf of one or more relying
parties, that trust service provider must pass on to each of the relying parties only that information which is
relevant.
4.3.3 Where personal data are processed on behalf of a data control er by a
third-party, the activities of the data processor must be governed by a written
contract. In addition to a written contract, providers of identity registration
services to government must comply with any applicable data protection and
retention policy.
5 Identity registration
5.1 Overview
5.1.1 Identity registration is the process by which a client registers a pseudonym,
or registers their real-world identity to a desired level of assurance. This may
include presentation of evidence by the client as proof of their real-world identity,
and checks to ensure that the evidence provided is authentic, valid and belongs
to the client. The real-world identity of a client need only be established if this is
essential to support the service(s) to be provided.
5.1.2 Identity registration typicaly involves provision of several forms of evidence
to support different elements of a client's real-world identity. For example, a client
might be required to provide a copy of their passport to confirm their name, date
of birth, etc and might also be required to provide a recent bank statement or
utility bil as evidence of recent activity at the address that they have given.
5.2 Identity registration process
5.2.1 Identity registration to support access to e-Government services may
proceed directly through a government service, or via a trusted third-party such
as the Government Gateway. Figure 5 presents a typical example of the identity
registration process. This process involves:
- a request by a client to register either their real-world identity or a
pseudonym;
- authentication of the e-Government service at a level of assurance that is
appropriate to protect the identity registration information provided by the client;44
- presentation by the client of any evidence requested by the service as proof
of their real-world identity;
- verification by the service provider of the real-world identity asserted by the
client, by checking that the evidence provided is authentic, valid and belongs to
the client.
44 Authentication of the service is discussed further at Section 7.
[Figure 5 deleted]
5.3 Impact level for identity registration
5.3.1 Identity registration attracts an impact level which is based on the highest
impact of a compromise of a client's real-world identity. This might include
impacts due to inaccuracy, duplication, improper assignment and/or
misappropriation of a client's identity registration information. The impact level for
identity registration is calculated using the HMG Impact Level table presented at
Annex D.
5.3.2 Services where a client may remain anonymous or where a client may
register using a pseudonym wil attract Registration IL0, even if a high level of
assurance is required for authentication of a client with a given pseudonym.45
5.3.3 Identity registration is pre-requisite to enrolment for many e-Government
services. Enrolment of a client requires the service provider to know whether the
client requesting the service is permitted to represent the real-world identity that
has been asserted. The impact level for the client's real-world identity wil thus be
at least as high as the impact level for any proof-of-entitlement submitted to
support enrolment. The correlation between identity registration and enrolment is
set out at Table 3. Enrolment is discussed in more detail at Section 6.
footnote 45 This would be the case, for example, where a client registers for a pseudonymous health-screening
programme. Such a service might well attract Registration IL0 and Authentication IL3.
[Table 3 deleted]
5.3.4 Integrity46 depends on the ability of the e-Government service to protect the
information assets that are entrusted to it, and also on the correctness of the
information provided. For cases where the impact level for integrity is determined
by a requirement for non-repudiation, the impact level for identity registration
must be at least as high as that for integrity.47 The mapping between identity
registration and integrity is set out at Table 4. Integrity is discussed in more detail
at Section 8.1.
[Table 4 deleted]
5.3.5 Information that is provided by a client during the identity registration
process has a value. This introduces a number of considerations for the identity
registration process:
- the measures that are in place to authenticate the e-Government service to
the client during the submission of identity registration information must be
commensurate with this value; further measures must be in place to protect the
information once within the service provision boundary;
- in general, the more confidence required in a client's real-world identity, the
higher the value of the identity registration information that the client wil need to
provide and the stronger the measures that must be in place to authenticate the
service during the identity registration process;
- protection of identity registration information is a particular issue for high-
value information such as biometric information that is captured for
46 The IS1 definition of integrity, which we have adopted for this document, includes the requirement for
non-repudiation of transactions and communications. 47 For example, if a service enables a range of
transactions at Integrity IL1 based on a requirement for non-repudiation, that client must be registered at
Registration IL1 or higher before being allowed to enrol.
checking against a national database;48 careful consideration of the options to
protect such information or reduce the impact of compromise would need to be
considered in such cases;49 applying measures for protection of high-value
identifiers is likely to be prohibitively expensive and difficult to implement in most
cases.
5.4 Threats
5.4.1 Potential clients might attempt to register using a fictitious real-world
identity, try to misappropriate a genuine real-world identity, or register false
details either deliberately or by accident.
5.4.2 These threats may be countered by examining original documents to an
appropriate level of scrutiny, checking the details given against population or
organisation registers or requiring that a trustworthy person or organisation
confirm the information given. There may also be technology-specific risks, which
should be addressed through the application of relevant technical guidance.
5.4.3 Appropriate measures must be in place to:
- ensure that clients are made aware of any identity registration information
that is or might be stored or archived on client machines and how to manage this
information;50
- authenticate the client to the service provider at an appropriate level of
assurance for the identity registration information being provided by the client;
- authenticate the service provider to the client at an appropriate level of
assurance for the identity registration information being provided by the client;
- protect identity registration information in transit and within the e-Government
service.
48 Widespread misappropriation of biometric information would negate the value of such a database.
Potential misuse of this information, for example to support fraudulent activities by a criminal organisation,
might lead the practitioner to assign a confidentiality impact level for this information that exceeds
Confidentiality IL3. 49 For the biometrics example, an example solution would be to securely process the
biometric using a hash function to present an identifier with significantly fewer degrees of freedom, but which
remains unique to an individual client insofar as the biometric itself can be considered unique. 50 For
example, cookies might be used to store identity registration information, to enable the registration process
to be paused. In this example, the client should be made aware of this, of the risks of using insecure
machines (eg in an internet café) and of how to expunge this information following registration.
5.5 General requirements
Registration evidence requirements
5.5.1 There wil be some services where anonymity or pseudonymous
registration of identity is acceptable (or sometimes even necessary). As a rule,
compliance with the DPA requires e-Government service provision to operate on
the principle of requesting the minimum information that is sufficient to enable
conduct of the required transaction or transactions.
5.5.2 Beyond the initial registration of a client's identity, there is a continual
requirement to ensure that the client's identity registration information is
amended as necessary, to reflect any change in their circumstances. This is
required to protect both the client51 and the e-Government service.52
Informing the client
5.5.3 Clients should be informed, at and/or before the point of identity
registration, of any further intended use of their identity registration information.
This may require careful consideration of what services or types of services for
which the client wil need to enrol.
Provision and maintenance of an electronic identity
5.5.4 Successful identity registration of a client might include provision of an
account and/or electronic identity for that client. If elements of a client's electronic
identity are to be delivered electronical y, both the client and the e-Government
service must be authenticated to an appropriate level of assurance to protect this
information. Alternatively, some or al of this information may be delivered to the
client via out-of-band channels to an independently verified address, telephone
number, etc. Authentication is discussed further at Section 7.
Trust relationships for identity registration
5.5.5 An e-Government service might act as its own identity registration authority,
or rely on a third-party to manage identity registration. There are a number of
mechanisms by which identity registration may be achieved, the most popular of
these mechanisms are discussed below.
5.5.6 The simplest relationship between a client and an identity registration
authority is two-party registration. An example of two-party registration would be
where a client registers directly with an e-Government service provider to use a
specific service or range of services delivered by the same service provider, but
would not be put to any further use. Two-party registration benefits from
simplicity of implementation, but may lead to an unnecessary
financial burden where a high level of assurance in the client's real-world identity
is required. For e-Government services, there is the additional disadvantage that
this approach may lead to a lack of consistency between e-Government services
and goes against the concept of joined-up government.
51 For example, by ensuring that information posted to clients is sent to the correct address. 52 For example,
by ensuring that the client is not provided with benefits for which they are no longer entitled.
5.5.7 Three-party registration involves a client registering their identity with an
identity registration authority which validates the client's real-world identity to a
number of e-Government service providers.53 Examples of three-party
registrations include initial registration for the government gateway or registration
with the proposed IPS identity database. In such cases some of the liability for
ensuring the client's real-world identity would be transferred from the service-
provider to the identity registration authority.
5.5.8 Many-party registration involves a client registering their identity with one of
several registration authorities, which validates the client's real-world identity to
the required level of assurance. Having registered with one registration authority,
the client's registration would be accepted to an appropriate level of assurance
by a federation of other registration authorities without needing to register again
with each of them. Many-party registration relies on the use of consistent or
equivalent methods across the federation of registration authorities for the
assessment and treatment of risk. Trust might be mediated by a third-party trust
service approval scheme such as tScheme or equivalent, or enabled through
bilateral or multilateral agreements between e-Government service providers.54
The balance-of-liability within such a model would require consideration.
5.5.9 Use of three-party or many-party registration is preferred over two-party
registration for e-Government service provision, to promote ease of accessibility,
consistency of service and economies of scale as discussed above.
Escalation of assurance in a client's real-world identity
5.5.10 There wil sometimes be a requirement to increase the level of assurance
in the real-world identity of a client who has already registered.55 Any such
escalation must require different evidence to that provided during the client's
initial identity registration.56
footnote 53 A broader definition of three-party registration would involve use of the registration authority to allow
clients to identify each other to a required level of assurance, in support of peer-to-peer transactions (the e-
Bay model of identity registration). 54 For example, if a service provider has registered a client at
Registration IL2, and an appropriate set of measures has been put into place to maintain that identity
registration information, other service providers with Registration IL2 assurance requirements and below
should be able to assert the client's identity without needing to gather further identity registration information
themselves. This would be subject to establishing a mutually agreeable trust relationship, and to explicit and
informed consent by the client. 55 This might be required, for example, if a client withes to enrol for
additional services or requires access to more sensitive functionality within a service for which they are
already enrol ed.
Accounting and audit
5.5.11 At Registration IL1 and above, client registration must be treated as an
accountable event. Accounting logs and audit information should be recorded,
supported by appropriate audit procedures to track and forensical y examine use
of the e-Government service as necessary.
5.6 Registration countermeasures
5.6.1 The levels of assurance required to support identity registration are as
fol ows:
- at Registration IL0 the e-Government service does not require any
confidence that the client is who they claim to be;
- at Registration IL1 the e-Government service wishes to ensure that, on the
balance of probabilities, the client is who they claim to be;
- at Registration IL2 the e-Government service requires substantial assurance
that the individual is who they claim to be;
- at Registration IL3 the e-Government service wishes to verify the client's
identity beyond reasonable doubt; at Registration IL3, the case for al owing
remote identity registration or online identity registration must be presented on a
service-by-service basis, agreed by the SIRO and thoroughly documented in the
RMADS; in particular, the Information Commissioner has advised that remote or
online identity registration should not be used for individuals where this identity
registration could permit access to personal information that could then be
manipulated.57
5.6.2 Table 5 and Table 6 provide an overview of the requirements for remote or
online identity registration of an individual and of an organisation respectively, in
comparison with the requirements for face-to-face identity registration. Any
identity registration procedures that are employed by service providers must be
commensurate with the procedures set out at Table 5 and Table 6. Caution must
be exercised when identifying appropriate remote or online registration
procedures. For example, use of online bil s, remittance advice and the like must
not be construed as constituting acceptable evidence of the client's address or
activity in the community; such evidence is trivial to forge.
5.6.3 Details of the specific items that constitute reputable evidence and
trustworthy sources may be found within the HMG minimum requirements
documents for the verification of the identity of individuals58 and organisations.59
These documents also include a further discussion of acceptable
countermeasures for the registration of individuals and organisations. In the
event of any disagreement, the evidence requirements set out at Table 5 and
Table 6 of this document take precedence over the HMG minimum requirements
documents.
56 This introduces a requirement to record what evidence was used during the initial registration process.
Where a trust model is in place between registration authorities and one registration authority might be
required to provide an escalation in the level of assurance provided by another registration authority, there
wil a requirement to make available the record of what evidence was used. This wil not necessarily require
the evidence itself to be exchanged. 57 This is to protect against fraudulent access to someone else's
personal data.
5.6.4 Annex E presents some examples of acceptable remote and online
evidence for the identity registration of an individual. Further support for
identifying the levels of countermeasures to be applied for identity registration
and authentication, and for identifying acceptable evidence to support identity
registration and authentication, are provided by the CSIA risk management tool.60
58 HMG's minimum requirements for the verification of the identity of individuals, Version 2.0, January 2003.
This document may be downloaded from the Cabinet Office web-site, http://www.cabinetoffice.gov.uk/. 59
HMG's minimum requirements for the verification of the identity of organisations, Version 2.0, January 2003.
This document may be downloaded from the Cabinet Office web-site, http://www.cabinetoffice.gov.uk/. 60
Enquiries relating to the risk management tool should be directed to CSIA via the contact provided at
Section 1.7.
[Table 5 deleted]
Footnotes: 61 In some cases, the client might be encouraged to provide some details (name, etc) to support
establishing a persistent pseudonym. This would general y not be mandatory and these details would not be
checked. 62 For face-to-face registration, one piece of reputable evidence of the client's identity or
corroboration from a trustworthy source, in addition to the client's signed personal statement, would be
sufficient. 63 If the registration authority holds its own detailed records, validation against these records may
count as one of the required trustworthy sources. 64 For face-to-face registration at Registration IL2, any two
of the fol owing, in addition to the client's signed personal statement, would be sufficient: 1 piece of
reputable evidence of the client's identity; 1 piece of evidence of the client's address; 1 piece of activity in
the community or third-party corroboration. 65 For face-to-face registration, this should contain the client's
signature and photograph. For remote or online registration, this should be a passport, other National
Identity document, or other document which provides an equivalent or higher level of assurance of a client's
identity. 66 For face-to-face registration at Registration IL3, in addition to the client's signed personal
statement and additional details, one piece of reputable evidence of the client's identity, 1 piece of evidence
of the client's address; 1 piece of activity in the community or third-party corroboration and one further piece
of evidence from the above would be required.
[Table 6 deleted]
67 Face-to-face registration by a representative at Registration IL1 would require any one of: evidence of
public registration (preferred); one piece of reputable evidence of trade or operational membership or of
dealings with government; or one piece of third-party corroboration from a trustworthy source. 68 Face-to-
face registration by a representative at Registration IL2 would require any one of: evidence of public
registration (preferred); two pieces of reputable evidence of trade or operational membership or of dealings
with government; or one piece of reputable evidence of trade or operational membership or of dealings with
government and one piece of third-party corroboration from a trustworthy source. 69 Face-to-face
registration by a representative at Registration IL3 would require evidence of public registration and one-or-
more pieces of reputable evidence of trade or operational membership or of dealings with government. 70
For face-to-face registration at Registration IL1, the organisation's representative would be required to
provide one piece of evidence of identity, one piece of evidence of affiliation with the organisation and one
piece of evidence of authority to act of the organisation. 71 For face-to-face registration at Registration IL2,
the organisation's representative would be required to provide one piece of evidence of identity, one piece of
evidence of affiliation with the organisation and one piece of evidence of authority to act of the organisation.
72 The face-to-face registration requirements for validating an organisation's representative at Registration
IL3 are equivalent to the remote registration requirements.
6 Client enrolment to a service
6.1 Overview
6.1.1 Enrolment is the process by which a client is enabled access to a specific
e-Government service. Enrolment is concerned with establishing the entitlement
of a client to receive an e-Government service (eg whether that client is eligible
for tax credits). Identity registration, by comparison, is concerned solely with
verifying the identity of a client. Before being enrol ed a client might first register
their real-world identity to an appropriate level of assurance, or a pseudonym,
with the service provider or a trusted third-party.
6.1.2 Successful enrolment of a client wil include provision of an account for that
client. Enrolment might also include provision of an electronic identity for that
client or might make use of an electronic identity that was issued during the
identity registration process. In some cases, use of an existing electronic identity
might require this to be extended. The strength of any authentication credential
provided during enrolment must be commensurate with the impact level attracted
to client authentication.
6.1.3 A client must enrol at or before first use of a service and may only use
those services for which they are enrol ed. Evidence requirements for enrolment
wil depend on the details of the service to be used and must be set in
conjunction with relying parties. 6.1.4 Enrolment for a service might be carried
out at the same time as identity registration73 or might be conducted after identity
registration.74
6.2 Enrolment process
6.2.1 Enrolment might proceed directly through the government service or
indirectly via a trusted third party. Figure 6 presents a typical example of the
enrolment process. This process involves:
- a request by a client to be enrol ed in the desired service or range of
services;
- authentication of the e-Government service at a level of assurance that is
appropriate to protect the enrolment information provided by the client;
- if a client has not previously been enrol ed in a service, registration of the
client's real-world identity may be required;
- a check of the entitlement of a client to have access to that service, or range
of services. This may require presentation of proof of status by the
client relevant to the service in question. This evidence must be verified by the
service to prove its authenticity and validity;
- an account and an electronic identity are provided to a client, which is
activated by a client. The account is recorded by government as having authority
to engage in the relevant transactions.
footnote 73 For example, if a client registers and enrols directly for a specific e-Government service. 74 For example if
a client registers with the Government Gateway and then enrols for a number of different e-Government
services, at different times, as the need arises.
[Fig 6 deleted]
6.3 Impact level for enrolment
6.3.1 Enrolment for an e-Government service attracts an impact level which is
based on the highest impact of al owing a client access to services to which they
are not entitled, or of denying a client access to services to which they are
entitled. The impact level for enrolment is calculated using the HMG Impact Level
table presented at Annex D.75 6.3.2 For cases where a real-world identity is
required, enrolment of a client requires the service provider to know:
- whether the real-world identity registered is eligible to receive the service
requested; this may require the provision of additional service-specific supporting
information;
- whether the client requesting the service is permitted to represent the real-
world identity that has been asserted; this requires the level of assurance in the
client's real-world identity to be at least as high as the level or assurance
required to support enrolment; for example, if a client wishes to enrol for a range
of services with Enrolment IL1 and Enrolment IL2, that client must first be
registered at Registration IL2 or higher. The correlation between identity
registration and enrolment is set out at Table 3 in Section 5;
- whether an escalation in the assurance of a client's real-world identity is
required to support enrolment;76
75 For example, if compromising a client's enrolment information is likely to cause minor financial loss to any
party then this would attract Enrolment IL2.
6.3.3 Some clients might wish to enrol to perform only some of the transactions
that are offered by an e-Government service (eg to support a lower level of
identity registration and enrolment). If an e-Government service is to enable such
a facility, appropriate access control measures and compartmentalisation of
services and information must be put into place.
6.3.4 Delegate accounts might attract a higher or lower impact level than
standard client accounts to reflect, for example, a requirement to manage many
client accounts or access to a more limited range of transactions. The enrolment
evidence requirements for delegates should reflect this.
6.3.5 The information that is provided by the client during the enrolment process
must be assigned a value, and protected in a manner that is commensurate with
this value (see the discussion at paragraph 5.3.5). This may require
authentication of the service provider during submission of this information.
6.4 Threats
6.4.1 Clients and other individuals who have registered their identity, stolen
somebody else's identity or subverted the registration process might attempt to
enrol for services that they are not entitled to. This might involve the provision of
a false proof of status, either deliberately or by accident. These threats might be
countered by, for example, examining original documents to an appropriate level
of scrutiny, checking the details given against other government back-end
system databases, or requiring that a trustworthy person or organisation confirm
the information given.
6.4.2 Appropriate measures must be in place to:
- ensure that clients are made aware of any enrolment information that is
stored on client machines and how to manage this information;
- authenticate the service provider to an appropriate level of assurance for the
enrolment information being provided;
- protect enrolment information in transit and within the e-Government service.
6.5 General requirements
Evidence of entitlement
6.5.1 Enrolment for a specific service might require the client to provide proof of
status, over-and-above that provided during identity registration, to establish 76 A
discussion of escalating the level of assurance in a client's real-world identity is provided at Section 5. A
discussion of how to protect such information during submission is provided at Section 7.
their entitlement.77 This information wil not necessarily correspond to an
escalation of existing identity registration information. Evidence provided by a
client during enrolment as proof of status should:
- be mandated by the service provider as a necessary precursor to service
delivery;
- not be concerned with proof of identity;
- represent the minimum additional information that is necessary to confirm
entitlement;
- not have already been demonstrated as part of the identity registration
process;
- not be part of (or derived from) the set of credentials issued at the time of
identity registration.
Provision and maintenance of an electronic identity
6.5.2 Successful enrolment of a client might include provision of an account
and/or electronic identity for that client. If elements of a client's electronic identity
are to be delivered electronical y, both the client and the e-Government service
must be authenticated to an appropriate level of assurance to protect this
information. Alternatively, some or al of this information may be delivered to the
client via out-of-band channels to an independently verified address, telephone
number, etc. Authentication is discussed further at Section 7.
6.5.3 Changes in a client's status or identity registration information might affect
their entitlement to receive an e-Government service. Identity registration and
enrolment information must be continual y updated.78 In the event that a client is
no longer eligible to receive a service or no longer wishes to receive that service,
appropriate procedures must be in place to manage disenrolment, along with
revocation of credentials and col ateral information.
Trust relationships for enrolment
6.5.4 A client who wishes to enrol for several e-Government services might, in
some cases, be required to submit the same (or similar) information, in addition
to their registration information, to support each enrolment.
footnotes: 77 For example, a client might be required to provide details of their income to support an application for tax
credits. 78 Mechanisms should be put into place to al ow clients to update registration and enrolment
information (address, telephone number, eligibility for the service etc) as-and-when this changes, and
encouraged to use these mechanisms. For many services, it is useful to require clients to re-enrol or refresh
their enrolment at regular intervals, obliging clients to update their enrolment and/or registration information.
The frequency and dates at which re-enrolment or refresh of enrolment information wil be require wil vary
depending on the service (for example, it might be useful to refresh client enrolment for tax credits at the
beginning or end of each financial year).
6.5.5 To eliminate duplication of effort, the client may wish to submit enrolment
information once and al ow it to be shared by al of the relevant service
providers:79
- where a three-party or many-party registration process is in place, enrolment
might be managed as an extension of the registration process;
- where mutual trust exists between two or more service providers, one service
provider might take prior enrolment of a client with another of the trusted service
providers as being in itself sufficient proof-of-entitlement to support enrolment.
6.5.6 Rather than require a client to submit evidence of entitlement to an e-
Government service, it may be preferable to obtain this evidence directly from
another (government or third-party) source.80 In such cases, the service provider
would need to provide sufficient assurance to the party supplying the information
that the confidentiality of the information disclosed wil be protected appropriately.
Delegate accounts
6.5.7 Any potential requirements to support delegate accounts,81 whereby a client
is given delegated authority to undertake actions on behalf of another client,82
must be considered as part of the service development process. This might
require both the delegate and the client they support to register their identities
before or at the time of enrolment. 6.5.8 Delegate accounts may require a
different enrolment process from standard client accounts:83
- a delegate acting in a professional capacity (as an accountant, for example)
might be required to undergo a primary enrolment as a delegate, and then be
linked to relevant client accounts, with an appropriate level of privilege;
- a delegate acting in a personal capacity on behalf of a relative might only
enrol once, but fol owing a different process to regular clients (reflecting, for
example, differing evidence requirements, levels of persistence, etc).
79 It is good practice to inform the client of any potential further use for their information in advance of
submission, and in some cases explicit prior consent will be required. 80 This would particularly be the case
where (a) the service provider requires a high level of confidence in the authenticity of the information
provided or (b) the submission of sensitive information is required to establish a client's entitlement, which
might be difficult to protect in transit from the client to the service provider but would be easier to protect
across a secure delivery channel between service providers. 81 A typical example would be the requirement
of a client to settle the accounts of a recently deceased family member. This would require the executor or
administrator of the wil to notify some service providers of the death and to settle financial accounts with
others. 82 Delegate accounts might be set up, for example, to establish and use a power of attorney or to
give a group of individuals "signing" responsibility for performing specific transactions such as accountancy
functions. 83 For a delegate acting on behalf of a recently deceased family member, the enrolment process
may wel require the delegate to provide, for example, proof of probate.
6.5.9 If a requirement to support delegate accounts is not explicitly met by an e-
Government service, alternative offline mechanisms must be provided to handle
such exceptions84 or an additional level of risk may have to be accepted by the
service provider.85
6.5.10 In some cases a delegate would be entitled to perform any transaction
offered by a service for the client on whose behalf they act. More general y, a
delegate would be authorised to perform some wel -defined subset of the
activities that the client they represent is able to perform (for example, an
accountant might be authorised to complete a client's tax returns, but might not
be authorised to change that client's address details).
6.5.11 A particular issue that must be considered during service design is
whether it is necessary to identify a specific individual carrying out an e-business
transaction on behalf of an organisation. The actual approach depends on the
underlying business process being supported. For example, it might be
appropriate for a purchase order to be placed by an identified organisation, with
the identity of the individual being managed by the organisation. Similarly, for
many transactions with central or local government, al that is of concern to the
citizen is that a transaction is with an identified organisation.
Accounting and audit
6.5.12 At Enrolment IL1 and above, client enrolment must be treated as an
accountable event. Accounting logs and audit information should be recorded,
supported by appropriate audit procedures to track and forensical y examine use
of the e-Government service as necessary.
6.6 Enrolment countermeasures
6.6.1 The levels of assurance required to support enrolment are as fol ows:
- Enrolment IL0 services are freely available to al and require no proof of
entitlement;
- Enrolment IL1 services require assurance that, on the balance of
probabilities, the client is eligible to receive the service offered;
- Enrolment IL2 services require substantial assurance that the client is eligible
to receive the service offered;
- Enrolment IL3 services require the client's entitlement to be confirmed
beyond reasonable doubt.
84 For example, using traditional channels. 85 For example, accepting that some delegates wil subvert the
identity registration and enrolment process by using the electronic identity of the client they represent.
6.6.2 In many cases, the information furnished to support client identity
registration wil be sufficient proof-of-entitlement for a service. Where additional
proof-of-entitlement is required, the procedures to support this should be
commensurate with those for identity registration at an equivalent impact level.
6.6.3 The information requirements to support enrolment wil vary on a service-
by-service basis. Generic information requirements for enrolment of a company's
representative in support of a company's representative are provided at Table 6
in Section 5.
6.6.4 In contrast to Registration IL3, which is difficult to manage using online
processes, Enrolment information at Enrolment IL3 and higher levels of
assurance may be easily communicated across secure channels, subject to
establishing appropriate trust relationship and putting appropriate measures into
place to support obligations under the DPA.
7 Authentication and client access
7.1 Overview
7.1.1 Authentication is the process by which a credential and col ateral
information are presented and verified, to establish a claim to a valid electronic
identity. An electronic identity to support authentication by a client would typical y
be provided during the identity registration and/or enrolment process.
7.1.2 For services where no authentication is required, prior identity registration
and enrolment need not take place. For other services, identity registration and
issue of an electronic identity are pre-requisite to authentication and use of an e-
Government service.
7.1.3 The level of assurance that is supported by an electronic identity relates
directly to the strength of the credential and of its col ateral information.86
7.2 Authentication process
7.2.1 Figure 7 presents the authentication process for a typical client session. It
also demonstrates where additional client authentication (for example to obtain
authorisation to carry out specific transactions) may be required. This process
typical y involves:
- presentation of a credential to the client by the e-Government service, and
checking of that credential by the client (or by a trusted third-party on behalf of
the client) to verify the electronic identity of the service;
- presentation of a credential to the e-Government service, and checking of
that credential by the e-Government service (or by a trusted third-party on behalf
of the service) to verify the client's electronic identity.
86 For example, the intrinsic strength of a cryptographic key wil depend on the key length and the algorithm
used, and on the complexity of any pin, password or passphrase that protects it.
[Fig 7 deleted]
7.3 Impact level for authentication
7.3.1 Client authentication attracts an impact level which is based on the highest
impact of compromise of a client's electronic identity. The impact level for client
authentication is calculated using the HMG Impact Level table presented at
Annex D.
7.3.2 A client may wish to perform a transaction within an e-Government service
which percolates through to other e-Government services (for example,
performing a universal change-of-address). This transaction would attract an
impact level equal to that of the highest impact of changing the relevant
information for any of the services involved.87
87 Previous e-Government guidance recommended that pan-service activities should attract a higher impact
level than single-service activities, noting the accumulated impact of al owing unauthorised changes to
propagate. However, adherence to minimum standards and the drive to support client convenience and trust
have led to a more homogeneous information environment, where registration requirements for different
services are supported by evidence requirements that are closely related or even the same. Similarly, the
implementation of HMG minimum standards has resulted in services whose service provision boundaries
have similar levels of resilience for a given impact level. Further, fol owing the IS1 risk assessment method,
by far the most significant source of risk to government information systems is due to external threat actors.
In this case, then, there are strong arguments that a threat actor who compromises one (properly
implemented) e-Government service is equal y able to compromise other such services, so that the "security
through diversity" argument no longer holds.
7.3.3 Promulgation of information across e-Government services as the result of
a transaction would require informed and explicit consent on the part of the client,
and is reliant on appropriate trust agreements being in place. The impact level for
authentication of the initiating service must be commensurate with the impact
level for integrity.
7.4 Threats
7.4.1 There are a number of threats relating to the authentication process. These
threats mainly relate to the vulnerability of client credentials and col ateral
information in transit and in use within potential y insecure environments.
Examples include:
- misappropriation of elements of a client's electronic identity through theft,
interception, cloning, forgery, cracking, network sniffing, keystroke loggers,
physical observation of client machines, social engineering, etc;
- deliberate misuse of service procedures (eg conduct of a Denial of Service
(DoS) attack through misuse of the client lockout feature);
- use of a credential for unintended purposes;
- use of a credential after a substantive change in circumstances;
- fraudulent use of a credential;
- undue withdrawal of a credential;
- bypassing the use of credentials.
7.4.2 Protection of high-value credentials, such as biometric information, is a
particular issue for service providers which must be careful y considered before
making a decision to use these, as discussed at Section 5.3.
7.5 General requirements Issue of credentials
7.5.1 An authentication credential wil , in general, correspond to a single real-
world identity. However, a real-world identity may possess a number of electronic
identities. It may be useful in some cases to re-use an authentication credential
for several different purposes. This is particularly the case for high value
credentials such as an Authentication IL3 token. For some such uses it may be
necessary to conceal or break the link between the electronic identity and the
client's real-world identity.88
7.5.2 For most electronic transactions, government wil accept credentials
provided, or partial y provided, by accredited third parties that register the identity
of clients and issue them with credentials and supporting information.
88 For example, if a client has registered their identity at Registration IL3 to receive an Authentication IL3
token and then wishes to use that token to support an application for a pseudonymous medical screening
programme with Registration IL0 and Authentication IL3.
Protection of credentials from theft and unauthorised use
7.5.3 As a general rule, a credential should support the minimum of information
that is necessary for it to function in an accessible form.
7.5.4 Where physical theft of a credential is a potential issue, measures should
be in place to require this credential to be delivered using an appropriately
secure electronic channel, delivered using an appropriate postal or courier
service, or issued in person to the registered client.
7.5.5 Where physical theft, electronic theft or unauthorised use of a credential
are potential issues, measures should be in place to ensure that this credential is
only usable in conjunction with col ateral information such as a PIN, password or
other user verification mechanism which is delivered separately.89
7.5.6 Clients should be made aware of (and agree to) any obligations to protect
electronic identities and shared secrets used for authentication.90 These
obligations (contractual or otherwise) must be supported by informing clients of
how to protect their electronic identities.
Authentication
7.5.7 An appropriate level of assurance of the electronic identities of both service
and client is required to enable effective authentication of each transaction. In
some cases this may require label ing individual transactions and use of workflow
management tools. Use of transaction label ing and management tools is
particularly important where there is a requirement for non-repudiation or
evidence of receipt to support formal or informal obligations.
7.5.8 Clients should be informed of, and encouraged to adopt best practice in
protecting their systems91 and any specialist requirements for specific services,
and should be made aware of the risks of using unsecured or public
access systems. Clients should also be informed of any measures to be taken
before, during and after a client session.92
89 Further information on the complexity requirements for credentials and col ateral information may be
found within the fol owing documents: CESG Infosec Memorandum Number 24, passwords, tokens and
biometrics used in combination for identification and authentication of users of government IT systems,
Issue 2.1, August 2004. CESG Infosec Memorandum Number 26, passwords for identification and
authentication, Issue 2.1, June 2004. CESG Infosec Memorandum Number 27, assessment of the
contribution of tokens to multi-factor identification and authentication systems CESG Infosec Memorandum
Number 28, performance and assurance standards for biometric systems contributing to multi-element
identification and authentication, Issue 1.0, January 2005. 90 A list of what these obligations are, supported
by a tick-box attached to a statement that the client confirms having read and agreed to the list of
obligations, would be sufficient in most cases. 91 For example use of a firewall and antivirus software,
employing a patching policy (eg using windows update or similar), using up-to-date browser software,
making use of publicly available guidance that is aimed at citizens, etc.
Protection of transactions against impersonation and interception
7.5.9 For authentication at Authentication IL1 or above, it wil general y be
necessary to secure information exchanges between a client and the e-
Government service to protect against man-in-the-middle and other
impersonation attacks.93 Protection might be applied for al of the transactions
within a client session, or only for some of these transactions at a level that is
tailored to the value of the transaction. This wil typical y require the use of
electronic signing for transactions whose impact level for integrity is Integrity IL1
or above, and/or use of cryptography for transactions at Confidentiality IL1 or
above. Normal commercial technologies and techniques should be employed
wherever possible to support this requirement.
Protection of service against bypass of client credentials
7.5.10 Appropriate measures must be in place to ensure that the e-Government
service is suitably robust against the bypass of client credentials. These
measures are discussed at Sections 0, 8.1 and 10.
Service management of electronic identities
7.5.11 Clear procedures for disenrolment of clients must be in place and
supported by clear guidelines for clients of how to disenrol and what the process
is for disenrolment.
7.5.12 Clients should be informed of exception-handling procedures that are in
place, such how to report theft loss or suspected compromise of credentials
and/or col ateral information and what the process is for revoking and replacing
these (eg how the replacement wil be sent and over what timescale). These
procedures should be easily accessible to clients, who should be encouraged to
use them if necessary.
7.5.13 For some e-Government services, it may be useful to restrict elements of
an electronic identity, for example by issuing credentials with a fixed lifespan or
automatical y revoking or disabling the authorisation of an electronic identity after
a defined period of disuse. In some cases it may be useful to establish client
usage patterns and disable the authorisation of an electronic identity if usage
deviates significantly from this profile.
92 Despite informing clients of best practice other measures, the measures that are in place to protect e-
Government services must be designed on the assumption that not all clients wil adopt the guidance given
and that some client machines wil have been compromised. 93 This might, for example, involve use of
SSL/TLS and registering the service provider's public key with a trusted third-party certification authority
such as Verisign.
Accounting and audit
7.5.14 Accounting logs and audit information should be recorded, supported by
appropriate audit procedures to track and forensical y examine use of the e-
Government service as necessary. This should cover not only transactions
between clients and the e-Government service, but should also cover
transactions involving government users.
7.6 Authentication countermeasures
7.6.1 The levels of assurance required to support authentication are as fol ows:
- Authentication IL0 has no requirement for any degree of trust in the client's
electronic identity;
- Authentication IL1 requires a moderate degree of trust in the client's
electronic identity;
- Authentication IL2 requires a substantial degree of trust in the client's
electronic identity;
- Authentication IL3 services require the client's electronic identity to be
confirmed beyond reasonable doubt. 7.6.2 Table 7 sets out the specific
requirements to support authentication at Authentication IL0 through
Authentication IL3.
[Table 7 deleted]
94 For example, use of SSL/TLS with 128/256-bit key or out-of-band distribution of part or al of credential.
95 For example, out-of-band distribution or use of a suitably encrypted digital certificate with out-of-band
distribution of a password (eg by post, telephone or text) via suitably assured contact details. 96 For
example, to enable personalisation of a service. 97 For example, use of a username and password or digital
certificate. 98 For example, use of a digital certificate. 99 CAPS-approved products would be required to
protect Authentication IL3 material and are recommended. Where this is not possible and an overwhelming
business benefit can be demonstrated, use of commercial best practice equivalent to Authentication IL2 may
be accepted in conjunction with limited lifespan authentication tokens and thorough Confidentiality/Integrity
IL3 Accounting and Audit measures. This measure is deprecated, owing to the significant degradation of the
security provided and is only acceptable where no reasonable alternative procedure is available. 100 For
example, ensuring that client information is not transmitted en bloc in clear. This might involve asking the
client to provide only a subset of a shared secret such as a password or using dynamic information relating
to a recent transaction. Other threats to be protected against should include, as a minimum, Trojans, disk
scavenging, keystroke loggers and network sniffing. 101 For example, a credential such as a digital
certificate might be protected by a PIN, password or other access control mechanism, and measures should
be in place to encourage protection of client machines and networks against malware. 102 For example, a
credential might be stored on a token and not exposed to the client machine. Alternatively, on presentation
of a credential to a central authentication server, an out-of-band method such as text messaging may be
used to transmit a unique one-time password to the client which can then be used to initiate the session. A
variation on this theme would be to issue the client with a password generator; this approach is currently
favoured by banks and other financial institutions. 103 Requirements for assurance of product, service and
system assurance, configuration testing (commercial best practice, penetration testing, etc) and the
compliance process are set out at Table 2
8 Confidentiality
8.1 Overview
8.1.1 Confidentiality covers the measures that are required to prevent the
unauthorised observation and disclosure of information that is stored and
handled by e-Government services. Measures must be in place to protect:
- provision of information by clients or government users;
- information in transit between a client system and an e-Government service;
- information stored by an e-Government services and information that is
exchanged between e-Government services;
- ancil ary information generated as a consequence of e-Government service
provision;104
- disposal and erasure of information.
8.1.2 Clients should be informed of how the information they provide wil be used
and shared, for instance warning individuals sending information into an HMG
domain that their communications may be monitored, recorded and retained.
8.2 Impact level for confidentiality
8.2.1 Confidentiality attracts an impact level which is based on the impact of
compromising an individual client's information,105 or compromise of an
information store. The impact level for confidentiality is calculated using the HMG
Impact Table presented at Annex D.
8.2.2 Al ocation of an impact level for confidentiality must explicitly consider
statutory requirements relating to protecting the confidentiality of personal
information and communications under the DPA, the Human Rights Act and
other legal instruments, and the consequences that a breach of confidentiality
might have.106 Potential Intel ectual Property Rights (IPR) issues might also
require consideration.
8.2.3 The impact of compromising an information store might be greater than the
impact of compromising an individual client's information, due to aggregation of
data or prolonged exposure to threats whilst in storage. This may require
protection under a more stringent regime (ie may require information stores to be
treated as if they were assigned to a higher impact level).
104 For example, systems management information and information on the performance and uptake of e-
Government services. 105 This includes information provided to support registration and enrolment as well
as information provided during use of the service. 106 This might include prosecution, damage to reputation
and other impacts; for example, the Information Commissioner has the power to order the cessation of
processing of personal data.
8.2.4 A smal subset of clients with uncommon circumstances may attract a
different impact level for confidentiality from the standard clients around whom
the service risks and impacts have been determined.107 There wil be similar
considerations for integrity and availability. Such exceptions should be identified
as part of the service development process and appropriate measures should be
put into place to manage such exceptions (offline methods, separate service
provision, provision of higher-assurance tokens to high-risk clients, etc).
8.2.5 If an e-Government service enables a client to access information that is
provided by a third-party, rather than information that is provided directly by the
client themselves, then the level of assurance for identity registration for the
receiving service must be at least as high as the level of assurance required for
the confidentiality of the information provided by the third party.
8.3 Use of protective markings and descriptors
8.3.1 Information that attracts an impact level for confidentiality may be label ed
using the PRIVATE descriptor, in the format: [PRIVATE], [Level n], [optional].108 n
is the impact level for confidentiality and the optional field al ows for a description
of the type of information.109 Information that is assessed as requiring Level 0 wil
not normal y attract the PRIVATE descriptor.
8.3.2 Within the protectively marked domain, information within the service
provision boundary that attracts Confidentiality IL3 should be treated in a manner
that is commensurate with RESTRICTED; this information should, however, not
be unreasonably withheld from the client that originated the information110 and for
this reason it may not be appropriate to explicitly label this information as
RESTRICTED.
8.4 Threats
Data-stores
8.4.1 The general threats to the confidentiality of e-Government data-stores are:
- that attack groups from outside the service provision boundary may gain
access to e-Government services for which they are not authorised;
- that authorised clients of e-Government services may access information that
they are not authorised to see;
- that attack groups may gain access to back-end systems.
8.4.2 Many of the threats to the confidentiality of data-stores may be countered
through suitably assured authentication and access control mechanisms,
supported by physical and procedural measures.
107 For example, the medical details of a celebrity might be of particular interest to the national press, and
any resulting publicity from such a disclosure might be embarrassing or cause significant distress. 108 Take-
up of the PRIVATE descriptor has been low across central government organisations. Many central
government organisations tend to protect e-Government service information assets internal y at a level
commensurate with RESTRICTED information assets, as this fits in with their existing business practices.
The PRIVATE descriptor has found more widespread use across local government, and across other wider
public sector organisations which are not bound to the protective marking scheme. 109 For example, medical
information concerning an individual might be marked as PRIVATE, Level 3, MEDICAL. 110 See the
discussion on clients at Section 3.2.
Information in transit
8.4.3 The general threats to the confidentiality of information in transit include
inadvertent disclosure, misdirection and interception of electronic
communications. Many of these threats may be countered using suitable
authentication and encryption mechanisms.
8.5 General requirements
8.5.1 Appropriate physical and procedural measures must be in place as
elements of a multi-layer approach to confidentiality, as discussed at Section 3.3.
8.5.2 Access to any registration and enrolment information, and to elements
relating to a client's electronic identity that are stored within an e-Government
service data-store, must be protected in line with the measures as set out at
Sections 5-7.
8.5.3 For Confidentiality IL1 and above, access controls must be implemented, in
line with the requirements set out at Section 7, to ensure that a user can access
only those elements of a service for which they are enrol ed and authenticated.
8.5.4 Access controls should be accounted for and regularly audited to keep
track of client access to information assets, supported by appropriate measures
to address any identified compromise. The integrity and availability of the
accounting logs themselves must be protected to a level of assurance which is,
as a minimum, commensurate with the confidentiality of the information assets
that they support.
8.6 Confidentiality IL0 countermeasures General
8.6.1 At Confidentiality IL0 no explicit protection is needed, though care should
stil be taken to adopt good system practice.
Access control and user access management
8.6.2 No access control mechanisms are required, although informal access
controls may be implemented.
Confidentiality of information in storage, use and transit
8.6.3 No explicit protection of information in transit and information stores is
needed, although care should sil be taken to adopt good system practice. Any
personal details submitted by a client must be properly protected in accordance
with the DPA.
Effective accounting and audit
8.6.4 No specific accounting and audit functionality is required.
Service protection
8.6.5 Adoption of normal good system practice for implementing and managing
network connections must be applied to prevent electronic attack.
8.6.6 There are no specific requirements for detection of electronic attack,
although checking of information-stores against regular backups is
recommended.
8.6.7 Measures in place to react to electronic attack must include an assessment
should be made of whether any damage, including loss of data integrity, has
occurred, and recovery of information-stores from the last known good backup.
The system should be restarted, as far as possible any damaged data should be
reloaded and external connections restarted.
8.7 Confidentiality IL1 countermeasures
General
8.7.1 At Confidentiality IL1 attention must be paid to correct system operation
and the use of basic access control. It is general y acceptable to use the in-built
security features of commercial products, configured correctly, but without
enhancement.
8.7.2 Information displayed on a screen or printed out should be afforded an
equivalent level of protection using physical and procedural security measures.
Confidentiality of information in storage, use and transit
8.7.3 Information within the service provision domain must be handled
responsibly and securely. Personal details submitted by a client must be properly
protected in accordance with the DPA. Some e-Government services wil require
enhanced measures to protect the real-world identity of clients.111
111 For example, services to support reporting of fraud or criminal activities
8.7.4 Appropriate measures must be in place to protect the confidentiality of
information in transit between the client and the e-Government service.112
Appropriate protection is also required to protect information exchanges between
e-Government services.
8.7.5 In order to handle information assets effectively, service providers must
ensure that there is a permanent binding between transaction material and the
security information that represents its confidentiality impact level, regardless of
the extent to which this information is split up for processing.
8.7.6 Appropriate measures must be in place to ensure secure erasure and
disposal of information assets once these are no longer required, and to ensure
that credentials which al ow access to information assets are revoked when a
client is disenrol ed113 from a service. The appropriate Security Operating
Procedures (SyOps) should be recorded in the RMADS.
8.7.7 The confidentiality of information assets might be compromised through
faulty hardware and software components. Use of components which have been
assured through the CCT Mark, CAPS, or a similar scheme should be preferred
during system design, to give confidence to system designers that the Vendor's
security functionality claims have been validated.
8.7.8 Encryption of data in storage and transit might be required for certain niche
areas.114
Effective accounting and audit
8.7.9 Basic client-related information should be recorded.115
8.7.10 The capability to carry out basic display and analysis of the accounting
records should be provided.
Service protection
8.7.11 Prevention of electronic attack on e-Government services should be
provided by:
- User application configuration: al government user applications capable of
processing imported material shal be configured to do so safely. For instance,
word processing and spreadsheet applications should preferably prevent
automatic macro execution without prior user permission or a detection strategy
should be in place.
- Import restrictions: the import of information objects from another domain
should be limited to information object types reasonably required to meet
business needs; al imported objects should be screened for recognisable
structures such as virus signatures. An anti-virus strategy with timely updates
should be implemented, subjecting imported information objects to content
analysis.
- User empowerment: the export of information objects from one domain to
another should be limited to information object types reasonably required to meet
business needs.
- Detection of electronic attack on e-Government services should be provided
at this level by:
- System monitoring: standard system-provided activity monitors should be
regularly examined to ascertain whether there is any suspicious activity or
pattern of activities that might indicate an electronic attack is being conducted. At
this level, consideration should be given to the use of host and/or network based
intrusion detection systems.
- Reviewing accounting logs: standard system-provided accounting logs
should be reviewed by appointed security personnel for the system to ascertain
whether there is any activity or pattern of activities that might indicate an
electronic attack has occurred.
footnote 112 This might include, for example, the use of SSL/TLS to encrypt a session, supported by appropriately
assured credentials for both the client and the e-Government service. 113 Disenrolment might occur, for
example, because the client no longer wishes to receive an e-Government service or is no longer eligible for
that service, and would typically be accompanied by sending a confirmation to the client. 114 For example,
encryption of password files 115 For example, client identifier, time of service access, transaction used,
success or failure of transaction
8.7.12 Reaction to electronic attack on e-Government services should be
provided at this level by:
- Incident response plan: an incident response plan, incorporating actions that
may range from immediate restoration of service to partial restoration or
suspension of service, should be documented and subjected to regular testing
and review.
- Control ed closedown: a control ed connection closedown process should be
available, maintaining the provision of essential business services as far as
possible.
- Impact assessment: an assessment should be made of whether any damage,
including loss of data integrity, has occurred and a recovery action plan drawn
up.
- Recovery: the system should be restarted; as far as possible any damaged
data should be reloaded and external connections restarted.
8.7.13 Appointed security personnel for the system should examine al incidents
of electronic attacks and determine whether any additional electronic or
procedural countermeasures should be put in place.
8.8 Confidentiality IL2 countermeasures
General
8.8.1 At Confidentiality IL2 auditable system operation and the use of stringent
access control are required. The use of suitably assured116 commercial
cryptographic products to provide access control is appropriate for some
purposes is required at this level.
8.8.2 An independent IT health check should be considered for al systems
hosting e-Government services. Information displayed on a screen or printed out
should be afforded an equivalent level of protection using physical and
procedural security measures.
Confidentiality of information in storage, use and transit
8.8.3 The fol owing measures must be in place, over and above those for
Confidentiality IL1, to protect the confidentiality of information in storage, use and
transit.
8.8.4 Government users who have access to personal client information must be
subject to at least as stringent requirements as clients. The information
accessible to system administrators must be the minimum necessary to meet the
business needs.
8.8.5 Commercial operating system access controls must be employed for
administrator access to systems.
8.8.6 Archived data must be stored such that only authorised and nominated
individuals (in accordance with Data Protection law) have the right to access the
data.
8.8.7 Strong access controls are required for access to bulk archive data. This
may be achieved by physical or electronic access controls. Encryption of
archives may permit the strong bulk data access control requirements to be
reduced to a more tractable key management task.
8.8.8 Data stored in a live environment (eg. on a database) must be protected by
strong access control. Encryption mechanisms present within the commercial
operating system and database products may offer benefits but must be used
only after their value has been established.
8.8.9 Information at Confidentiality IL2 should be processed on a system to which
only authorised government users have physical access and should be password
protected.
116 Cryptographic products to protect information at Confidentiality IL2 must be assured using the CCT Mark
or an equivalent scheme, to EAL2 or above.
8.8.10 Processes handling information at Confidentiality IL2 should be routinely
penetration tested to check for any inadvertent data leakage.
8.8.11 The required protection for data in transit depends upon the nature of the
communications path. For services provided over open networks, such as the
Internet, some form of commercial encryption is appropriate. In the case of web-
based services, HTTPS wil usual y be the most convenient protocol, owing to its
inclusion in commercial web browsers. S/MIME is currently the standard for
secure email.
Effective accounting and audit
8.8.12 Measures to support accounting and audit wil be similar to those for
Confidentiality IL1, but accounting logs must be protected at a level appropriate
for Confidentiality IL2 and more regular auditing wil be required.
Service protection
8.8.13 Prevention of electronic attack on e-Government services should be
provided by:
- User application configuration: al government user applications capable of
processing imported material shal be configured to do so safely. For instance,
word processing and spreadsheet applications should preferably prevent
automatic macro execution without prior government user permission or a
detection strategy should be in place.
- Import restrictions: a business case and risk assessment should be provided
for each information type to be imported; al imported objects should be screened
for recognisable structures such as virus signatures. An anti-virus strategy with
timely updates should be implemented, subjecting imported information objects
to content analysis. Al import requests shal be recorded to meet specified audit
requirements enabling trend analysis to be performed. Website access should be
granted explicitly subject to a business case, and limited to known and `trusted'
sites. Active web content should be removed on import or executed in a
control ed safe space. E-mail attachments should be limited to permitted types.
- User empowerment: a business case and risk assessment should be
provided for each information type to be exported.
- Export restrictions: government users must be made aware of al items
selected for export, as hidden information might be included (such as deleted text
in a word processor file).
8.8.14 Detection of electronic attack on e-Government services should be
provided at this level by:
- Intrusion detection: host and/or network based intrusion detection systems
should be used, in addition to the monitoring of standard system-provided activity
monitors, to ascertain whether there is any suspicious activity or
pattern of activities that might indicate an electronic attack is being conducted.
- Reviewing accounting logs: standard system-provided accounting logs
should be reviewed by appointed security personnel for the system, to ascertain
whether there is any activity or pattern of activities that might indicate an
electronic attack has occurred. At this level, consideration should be given to the
use of automated audit tools.
8.8.15 Reaction to electronic attack on e-Government services should be
provided at this level by:
- Incident response plan: an incident response plan, incorporating actions that
may range from immediate restoration of service to partial restoration or
suspension of service, should be documented and subjected to regular testing
and review.
- Control ed closedown: a control ed connection closedown process should be
available, maintaining the provision of essential business services as far as
possible.
- Impact assessment: for each electronic attack identified, an assessment
should be made of whether any damage, including loss of data integrity, has
occurred and, if necessary, a specific recovery action plan drawn up in line with
the guidance in the incident response plan.
- Recovery: the system should be restored; as far as possible any damaged
data should be reloaded and external connections restarted. 8.8.16 Appointed
security personnel for the system should examine al incidents of electronic
attacks and determine whether any additional electronic or procedural
countermeasures, including changes to the incident response plan, should be put
in place.
8.9 Confidentiality IL3 countermeasures
General
8.9.1 At Confidentiality IL3 auditable system operation and the use of stringent
access control is required. Use of cryptography to provide access control is
anticipated at this impact level, as discussed at Section 7.
8.9.2 An independent IT health check is required at Confidentiality IL3.
Information displayed on a screen or printed out should be afforded an equivalent
level of protection using physical and procedural security measures.
Confidentiality of information in storage, use and transit
8.9.3 There is a strong requirement for protection of data via access control:
- Providers and system administrators of e-Government services who have
access to personal client information should be subject to at least as
stringent requirements as clients. The information accessible to system
administrators should be the minimum necessary to meet the business needs.
- Consideration should be given to ensuring that al government users of
systems processing or handling information at Confidentiality IL3 should be
subject to a Basic Check security clearance.
- Commercial operating system access controls should be employed for
administrator access to systems.
- Archived data should be stored such that only authorised and nominated
individuals (in accordance with Data Protection law) have the right to access the
data.
- Strong access controls are required for access to bulk archive data. This may
be achieved by physical or electronic access controls. Encryption of archives
may permit the strong bulk data access control requirements to be reduced to a
more tractable key management task. 8.9.4 Data stored in a live environment (eg
on a database) should be protected by strong access control. Encryption
mechanisms present within the commercial operating system and database
products may offer benefits but should be used only after their value has been
established.
8.9.5 Information that attracts Confidentiality IL3 should only be processed on a
system to which authorised government users have physical access and should
be password protected. 8.9.6 Processes handling information that attracts
Confidentiality IL3 should be tested to check for any inadvertent data leakage.
8.9.7 The required protection for data in transit depends upon the nature of the
communications path. For services provided over open networks, such as the
Internet, some form of commercial encryption is appropriate. In the case of web-
based services, HTTPS wil usual y be the most convenient protocol, owing to its
inclusion in commercial web browsers. S/MIME is currently the standard for
secure email. The details of how these protocols are implemented must be
considered by the service provider.117
Effective accounting and audit
8.9.8 Relevant client-related information should be recorded for each
transaction.118
8.9.9 Capabilities to carry out display and detailed data-mining and analysis of
the accounting records must be provided.
117 A discussion of the proper implementation of HTTPS and S/MIME is provided within CESG Infosec
Manual T, passwords, transport layer protocol implementation recommendations for HMG protectively-
marked material, Issue 1.0, January 2001. 118 For example, client identifier, time of service access,
transaction used, success or failure of transaction, current transaction status.
Service protection
8.9.10 Prevention of electronic attack on e-Government services should be
provided at this level by:
- User application configuration: al user applications capable of processing
imported material shal be configured to do so safely. For instance, word
processing and spreadsheet applications should preferably prevent automatic
macro execution without prior government user permission or a detection
strategy should be in place.
- Import restrictions: a business case and risk assessment should be provided
for each information type to be imported; al imported objects should be screened
for recognisable structures such as virus signatures. An anti-virus strategy with
timely updates incorporating anti-virus products (the use of two products should
be considered) should be implemented, subjecting imported information objects
to content analysis. Al import requests shal be recorded to meet specified audit
requirements enabling trend analysis to be performed. Website access should be
granted explicitly subject to a business case, and limited to known and `trusted'
sites. Active web content should be removed on import or executed in a
control ed safe space. E-mail attachments should be limited to permitted types.
- User empowerment: a business case and risk assessment should be
provided for each information type to be exported.
- Export restrictions: government users must be made aware of al items
selected for export, as hidden information might be included (such as deleted or
original text in a word processor file).
8.9.11 Detection of electronic attack on e-Government services should be
provided at this level by:
- Intrusion detection: host and/or network based intrusion detection systems
should be used, in addition to the monitoring of standard system-provided activity
monitors, to ascertain whether there is any suspicious activity or pattern of
activities that might indicate an electronic attack is being conducted.
- Reviewing accounting logs: automated audit tools should be used by
appointed security personnel for the system to examine standard system-
provided accounting logs to ascertain whether there is any activity or pattern of
activities that might indicate an electronic attack has occurred.
8.9.12 Reaction to electronic attack on e-Government services should be
provided at this level by:
- Incident response plan: an incident response plan, incorporating actions that
may range from immediate restoration of service to partial restoration or
suspension of service, should be documented and subjected to regular testing
and review. There should be a properly trained Computer Incident Response
Team (CIRT).
<li>Incident recovery procedures: there should be detailed incident recovery
operating procedures to be fol owed in the event of an attack, based on the
incident response plan.
- Control ed closedown: a control ed connection closedown process should be
available, maintaining the provision of essential business services as far as
possible.
- Impact assessment: for each electronic attack identified, an assessment
should be made of whether any malicious damage, including loss of data
integrity, has occurred and, if necessary, a specific recovery action plan drawn
up in line with the guidance in the incident recovery procedures.
- Recovery: the system should be restored; as far as possible any damaged
data should be reloaded and external connections restarted.
8.9.13 Appointed security personnel for the system should examine al incidents
of electronic attacks and determine whether any additional electronic or
procedural countermeasures, including changes to the incident response plan
and/or incident recovery procedures, should be put in place.
9 Integrity
9.1 Overview
9.1.1 Integrity covers ensuring and maintaining the accuracy of information that is
stored and handled by e-Government services. Measures must be in place to
ensure:
- the accuracy of information provided by clients or government users and the
ability of al parties to rely on that information to support transactions where
required; this includes evidence to support informal,119 formal or legal y binding
agreements between parties;
- protection of information provided by clients or government users;
- protection of information in transit between a client system and an e-
Government service;
- protection of information stored by an e-Government services and information
that is exchanged between e-Government services;
- protection of ancil ary information generated as a consequence of electronic
service provision.120
9.1.2 Integrity depends upon protection of the e-Government service provision
domain as a whole against external attack, and on the use of robust and reliable
business service applications and infrastructure.
9.2
Impact level for integrity
9.2.1 Integrity attracts an impact level which is based on the impact of
- compromising the accuracy of an information store or of an individual client's
information;
- not having sufficient confidence in the integrity of information to support
legal y binding commitments121, including:
- commitments made by government to the client;
- commitments made by the client to government;
- ensuring an appropriate level of proof to support trust service transactions.
119 "Informal" agreements may include, for example, email correspondence where one party promises to
conduct an activity. Although this might not constitute a formal or binding agreement, non-repudiation of
such discussions may be useful in the case of a dispute. 120 For example, systems management
information and information on the performance and uptake of e-Government services. 121 Similar
considerations apply for less formal commitments.
9.2.2 The impact level for integrity is calculated using the HMG Impact Level
table provided at Annex D.
9.2.3 There is a reasonable overlap between the countermeasures that support
integrity and those that support confidentiality, in that effective access control and
exception handling mechanisms are required. As a result of the requirement for
effective access control, a transaction that requires a high level of assurance for
integrity is likely to require an equivalent or higher level of client authentication.
9.2.4 If an e-Government service provides clients with benefits based on the
information they have provided, then the impact levels for identity registration and
enrolment must be at least as high as that for integrity. The mapping between
identity registration and integrity for such cases is set out at the left-hand table
within Table 4 at Section 6 and also extends to enrolment.
9.2.5 When al ocating an impact level for integrity, service providers must
consider the effect of inadvertent disclosure of sensitive information on the public
perception of security and reliability for e-Government services. Similarly, a
malicious attack on the integrity of a seemingly low value service122 might have a
disproportionate effect on the public perception of e-Government services as a
whole.
9.3 Threats
9.3.1 There is significant overlap between the general threats to the
confidentiality of information assets (as discussed at Section 8.4) and the threats
to the integrity of those assets. Threats that are specific to integrity relate to non-
repudiation of contractual y binding transactions, evidence of receipt and trusted
commitment services.
9.4 General requirements
General
9.4.1 There is a degree of overlap between the countermeasures that support
confidentiality and those that support the integrity of services and their
information assets. Physical and procedural measures, access control and user
access management, effective accounting and audit and service protection
measures must al be in place. The countermeasures that are required for these
aspects of e-Government services, to support integrity at a given level of
assurance, must be commensurate with the countermeasures implemented to
support confidentiality at an equivalent level of assurance, as discussed at
Section 8.
122 For example, defacing a government web site or altering the content of publicly available government
information.
9.4.2 Similarly, use of components which have been assured through the CCT
Mark, CAPS, or a similar scheme should be preferred during system design, to
give confidence that these wil function as stated by the Vendor.
9.4.3 Clients and other users of e-Government services must be confident in the
correctness, completeness, and authority of information and advice received in
an e-Government service transaction and that anything they submit wil be
correctly received. This covers both erroneous information and information
inadvertently or maliciously altered during storage, processing or transit.
Non-repudiation
9.4.4 There must be a sufficient level of assurance that transactions enacted by a
client can only have been carried out by the rightful holder of an electronic
identity. This frustrates attempted denial of responsibility for fraudulent use.
Moreover, clients need to be assured that the service providers cannot repudiate
the service provider's part of a transaction. Equal y service providers might wish
to be assured that government cannot repudiate its part in a transaction either.
9.4.5 Threats to the non-repudiation of binding transactions may be met by
appropriate levels of evidence requirements for identity registration, enrolment
and authentication, supported by appropriately assured label ing and
management of transactions. This may include a requirement to retain archive
data. There is a requirement to establish what information should be retained and
for how long. Any responsibility on the client for retention of evidence must be
clearly communicated. Where evidence is required to be retained securely for an
extended period, consideration must be given to the natural degradation of
encryption technology over time.
9.4.6 A transaction may be comprised of several elements, involving more than
one department or process.123 Measures to support non-repudiation might be
required at a number of points for such a transaction. Such measures would
enable the relevant parties to determine who originated the transaction, whether
the transaction received matches the transaction sent, and whether the
transaction was accepted by the recipient. For such cases, service providers wil
need to determine not only what measures are required, but also at what points
and how to coordinate them. Non-repudiation may also be required for other
communications between e-Government services and trusted third-parties that
are necessary to provide an end-to-end service.
Evidence of receipt
9.4.7 Clients and other users (including service providers) of the services must
be able to demonstrate that transactions submitted have actual y completed and
that they cannot be falsely accused of failure to submit required returns or deny
receipt of information.
123 For example, a change of address request that spans multiple e-Government services.
Trusted commitment service
9.4.8 Authorised clients of e-Government services must be confident that (for
example) their authorities for payment wil be properly control ed and are not
vulnerable to fraudulent use of their means of payment, subject to the clients
keeping relevant credentials or other personal information secure.
9.5 Integrity IL0 countermeasures
Integrity of information
9.5.1 Physical and procedural measures, access control, user access
management, accounting and audit and service protection measures in line with
those required to support Confidentiality IL0 must be in place. 9.5.2 Existing
protocols should be used to provide simple protection for data in transit. It should
be possible to determine where modification has occurred.124
Non-repudiation
9.5.3 No measures for non-repudiation are required at this level.
9.5.4 If simple assurance that a transaction or an object originated from a
purported source is desired, the electronic and/or real-world identity of the
originator and, optional y, a transaction reference number, might be used to
support this.
9.5.5 No additional mechanisms over and above the normal service elements are
required. For example, email identified as originating from user@dept.gsi.gov.uk
may be assumed to originate from "user"; for web services, the page presented
by http://www.dept.gov.uk/ may be assumed to originate from that department.
Evidence of receipt
9.5.6 Existing service mechanisms are used to provide simple assurance that an
object has been received by the recipient.125
9.5.7 No additional mechanisms over and above the normal service elements of
the system are provided. For example, an email reply stating that a transaction
has been received or the display of a web page acknowledging a request is
sufficient.
124 For example, document format errors or incomplete web pages 125 The measures here only give
evidence that the transaction has been received by the recipients communications equipment or electronic
address. If evidence is required that a specified real-world identity has received the transaction, a higher
level of trust should be used for which the receipt is bound to the recipient identity.
9.6 Integrity IL1 countermeasures
Integrity of information
9.6.1 Physical and procedural measures, access control, user access
management, accounting and audit and service protection measures in line with
those required to support Confidentiality IL1 must be in place.
9.6.2 Use of message integrity features and checksums within standard
communications protocols provide adequate protection against accidental
corruption of a message. If greater assurance in the message integrity is
required, informal mechanisms involving passwords and PINs may be adopted.
Non-repudiation
9.6.3 Effective non-repudiation at Integrity IL1 is unlikely to be achievable.
Measures that may be applied are essential y as for Integrity IL0, with some
review of the system configuration to ensure that the standard services and
protocols are not obviously vulnerable to attack.
9.6.4 Additional degrees of trust may be achievable by the use of informal
technical measures such as the agreement of passwords via out-of-band
routes.126 These passwords may then be used with simple encryption or signing
tools to demonstrate possession of the password to correspondents. Another
simple technique to reduce the scope for later repudiation is to provide the client
at intervals with a list of transactions to date.
9.6.5 It is important that expert guidance be sought when setting up non-
repudiation schemes, as the additional trust achieved is often il usory unless the
scheme is careful y constructed. Such schemes are rarely foolproof, it is
therefore important that the limits of such schemes are understood and accepted
by parties to the transaction. However, these methods may support a useful extra
degree of trust in specific cases and provide the client with greater confidence.
9.6.6 Appropriate accounting log files should be kept, showing transaction times
and records of system operation.
Evidence of receipt 9.6.7 Evidence of receipt would typical y be achieved at this
level by returning evidence of possession of the message to the originator under
a non-repudiation service. Close attention to system configuration possibly
supported by informal mechanisms may be used to achieve this in line with the
Integrity IL1 non-repudiation approach.
126 For example, printed correspondence.
9.7 Integrity IL2 countermeasures
Integrity of information
9.7.1 Physical and procedural measures, access control, user access
management, accounting and audit and service protection measures in line with
those required to support Confidentiality IL2 must be in place.
9.7.2 A transaction or a digest of the transaction, signed using an appropriately
strong credential, must be used to provide evidence of integrity.127
9.7.3 The signature must be verified by the recipient of the transaction.
9.7.4 Modifications or errors in the signed object, whether accidental or
deliberate, wil cause verification of the signature to fail.
Non-repudiation
9.7.5 A transaction or a digest of the transaction, signed by the originator, must
be used to provide evidence of origin.
9.7.6 The signature must be verified by the recipient of the transaction, or by a
third party.
9.7.7 Ownership of any public keys must be verified by a recognised entity, which
may be the recipient or some other party.
9.7.8 Appropriate accounting log files must be kept, showing transaction times
and records of system operation.
9.7.9 At this level, it may be appropriate to include a means for providing a record
of the transaction as seen by the client.
Evidence of receipt
9.7.10 Trusted commitment services require that the commitment information
provided be protected with an appropriate level of non-repudiation, proof-of-
receipt and integrity.
9.8 Integrity IL3 countermeasures
Integrity of information
9.8.1 Physical and procedural measures, access control, user access
management, accounting and audit and service protection measures in line with
those required to support Confidentiality IL3 must be in place.
127 See the discussion on Authentication at Section 7.
9.8.2 The measures to protect the integrity of information at Integrity IL3 are
similar to those for Integrity IL2 except that a stronger credential wil general y be
required.128
Non-repudiation
9.8.3 The measures to support non-repudiation at Integrity IL3 are similar to
those for Integrity IL2, with the mechanism used to identify ownership of the
public key provided by approved mechanisms.
9.8.4 In addition, products and systems must provide appropriate protection for
private keys and use standardised formats and protocols.
9.8.5 Appropriate accounting log files must be kept, showing transaction times
and records of system operation. At this level, it may be appropriate to include a
means for providing a record of the transaction as seen by the client.
Evidence of receipt
9.8.6 Evidence of receipt would typical y be achieved at this level by a response
demonstrating receipt returned to the transaction originator:
- The returned response must be protected by an integrity service and a non-
repudiation service.
- The response may be generated manual y or automatical y. 9.8.7 Evidence of
receipt may be provided by a system that can provide a combination of a Integrity
IL3 non-repudiation and Integrity IL3 integrity services.
128 See the discussion on Authentication at Section 7.
10 Availability
10.1 Overview
10.1.1 Availability covers the measures that are required to ensure that clients
can access e-Government services and transact with those services as required.
This involves protection of data-stores and putting appropriate business
continuity plans in place to protect online service provision and to provide offline
alternatives in the event of failure.
10.2 Impact level for availability
10.2.1 Availability attracts an impact level which is based on the impact of an
authorised client not being able to transact with an e-Government service. The
impact level for availability is calculated using the HMG Impact Level table
presented at Annex D.
10.2.2 A smal subset of clients with uncommon circumstances may attract a
different impact level for availability from the standard clients around whom the
service risks and impacts have been determined.129 There wil be similar
considerations for confidentiality and integrity. Such exceptions should be
identified as part of the service development process and appropriate measures
should be put into place to manage such exceptions.
10.2.3 The implications of e-Government service failure may vary depending on
factors such as the time of year. For example, outage of an application al owing
electronic submission of tax returns is likely to be much more of a problem in the
week before the tax return filing deadline than at other times in the year. Such
services wil attract a disproportionately high impact level for availability. This
may be mitigated by having a business continuity plan which makes provision for
such eventualities (for example, by enabling alternative offline means of service
provision and al owing a relaxation of deadlines in the event that the service fails
at an inopportune time). If such a plan were in place, then the availability impact
level would be reduced accordingly.
10.2.4 When al ocating an impact level for availability, service providers must
consider the effect of non-malicious service failure on the public perception of
security and reliability in e-Government services.
10.3 Threats
10.3.1 The general threats to the availability of e-Government data-stores and
information in transit are:
- that unauthorised attackers from outside the service provision boundary may
disrupt e-Government services by bypassing boundary protection
129 For example, identity and address details of "at risk" groups who may be in need of emergency medical
care.
measures, attacking connected systems, attacking the internet or other relevant
information environment, misusing security measures, information overload
attacks, etc;
- that authorised clients of e-Government services wil deliberately or
accidental y compromise these services;
- that data-stores wil be subject to unforeseen failure, physical attack or
natural disasters.
10.4 General requirements
10.4.1 There is a degree of overlap between the countermeasures that support
confidentiality and those that support the availability of services and their
information assets. Physical and procedural measures, access control and user
access management, effective accounting and audit and service protection
measures must al be in place. The countermeasures that are required for these
aspects of e-Government services, to support availability at a given level of
assurance, must be commensurate with the countermeasures implemented to
support confidentiality at an equivalent level of assurance. 10.4.2 Similarly, use
of components which have been assured through the CCT Mark, CAPS, or a
similar scheme should be preferred during system design, to give confidence that
these wil function as stated by the Vendor.
10.5 Availability IL0 countermeasures
Service availability
10.5.1 Normal good system practice must be adopted in respect of designing,
implementing and managing the service. It is likely that no explicit availability
measures wil be required.
Information availability
10.5.2 No special measures need be taken to ensure data backup or continuity of
service fol owing an interruption to service. Business continuity must stil ,
however, be considered.
10.5.3 In particular, no special measures need to be taken to recover partial y
completed transactions, other than for those that affect the integrity of existing
information.
10.6 Availability IL1 countermeasures Service availability
10.6.1 Availability for the service must be compatible with the assessment of the
business need. Uptime requirements wil vary depending on the service to be
provided, but indicative availability requirements would general y be expected
to be better than 99% uptime with no unplanned service break of more than 20
minutes and no more than 1 unplanned service break in any 24 hour period.
10.6.2 Careful consideration must be given to sizing of the communications and
information systems so as not to compromise availability. The sizing must be
based on realistic estimates of demand for the service.
10.6.3 Alternative communications plans that can be switched in within the
timescale appropriate to the business need must be available. It is likely that
immediate failover wil not be necessary.
10.6.4 Battery backup must be provided to al ow `soft' failure with power recovery
achievable within the timescale appropriate to the business need.
10.6.5 A configuration management plan and processes covering the service
must be designed and implemented. Configuration changes must be approved
by the service manager before implementation. Software must only be introduced
with the approval of the service manager.
10.6.6 A failure impact analysis must be carried out and recorded for al
information and communication system components. This must be reviewed in
the event of significant configuration changes.
10.6.7 A business continuity plan must be in place and subject to regular
rehearsal and review. The plan must address: management roles and
responsibilities for business continuity; recovery procedures and audit trail;
security specific recovery actions.
Information availability
10.6.8 No special measures need be taken to ensure data backup or continuity of
service fol owing an interruption to service. In particular, no special measures
need to be taken to recover partial y completed transactions, except for those
that affect the integrity of existing information.
10.6.9 Information back up must fol ow commercial best practice and enable
restoration of al relevant information to within one week of the current date.
Commercial best practice must be fol owed with a ful weekly backup and daily
incremental backups. The restoration process should be documented in the
business continuity plan and tested regularly.
10.6.10 A process must be available to provide access for a client to his/her
client account in the event of loss of a password.
Page 90 Availability
10.7 Availability IL2 countermeasures
Service availability
10.7.1 Availability for the business service to be provided must be compatible
with the assessment of the business need. Current good commercial architecture
must be implemented.130 Service Level Agreements (SLAs) for external y
provided services must be set to meet the availability requirements for
transactions and information items. Uptime requirements wil vary depending on
the service to be provided, but indicative availability requirements would
general y be expected to be of order 99.5% uptime with no unplanned service
break of more than 15 minutes and no more than 1 unplanned service break in
any 24 hour period. Particular consideration must be given to the availability
requirements for accounting logs.
10.7.2 Careful consideration must be given to sizing of the communications and
information systems so as not to compromise availability. The sizing must be
based on realistic estimates of demand for the e-Government service.
10.7.3 Uninterruptible Power Supplies (UPS) must be used to al ow `soft' failure.
Power recovery must be achievable within the timescale appropriate to the
business need at Availability IL2.
10.7.4 Alternative communications paths that can be switched in within the
timescale appropriate to the business need at Availability IL2 must be available.
At this level consideration must be given to the use of alternative
communications paths with immediate failover.
10.7.5 A configuration management plan and processes covering the
communications and information systems providing the service must be designed
and implemented. Operational and security configuration must be checked for
compliance with documentation, supplemented by a penetration test in
accordance with commercial best practice. Configuration changes must be
approved by the service manager before implementation and must be subject to
secure audit (technical or procedural). Software must only be introduced with the
approval of the service manager and a ful inventory of al hardware and software
and a network diagram showing al approved connections must be maintained.
10.7.6 Failure impact analysis must be carried out and recorded for al
information and communications components. This must be reviewed in the
event of significant configuration changes. No upgrades wil be permitted without
prior offline testing and assessment.
10.7.7 A commercial best practice self-test process must be in place. 130 For
example, use of multi-tier, high redundancy architectures (eg redundant processor configurations, mirrored
disks, RAID arrays etc) and geographical distribution.
e-Government framework for Information Assurance Draft 5.1 Page 91
10.7.8 A business continuity plan must be in place and subject to regular
rehearsal and review. The plan must address: management roles and
responsibilities for business continuity; recovery procedures and audit trail;
security specific recovery actions.
Information availability
10.7.9 It is required to identify partial y complete transactions that might have
failed in the event of non-malicious failure and to inform the parties involved
accordingly. However, no special measures need be taken to recover partial y
completed transactions except for those that affect the integrity of existing
information.
10.7.10 Information back up must enable restoration of al relevant information to
within one day of the current data. Commercial best practice must be fol owed
with a ful weekly backup and daily incremental backups, preferably supported by
a continual backup process. The backup must be compared against the original
before the backup media is stored offsite. The restoration process must be
documented in the business continuity plan and tested regularly.
10.7.11 Baseline level cryptographic checksums or secure software isolation for
system software, configuration data and storage facilities must be provided. A
secure self-test process must be undertaken regularly using these facilities.
10.7.12 A process must be available to provide access for a client to his/her
client account in the event of loss of a password or access token.
10.8 Availability IL3 countermeasures
Service availability
10.8.1 The availability of the overal business service and individual transactions
must be compatible with the assessment of the business need. Current good
commercial practice architecture design must be used.131 SLAs for external y
provided services must be set to meet the availability requirements for
transactions and information assets. Uptime requirements wil vary depending on
the service to be provided, but indicative availability requirements for the service
would general y be expected to be of order 99.9% uptime with no unplanned
service break of more than 5 minutes and no more than 1 unplanned service
break in any 48 hour period. Particular consideration must be given to the
availability requirements for accounting logs. 10.8.2 Careful consideration must
be given to sizing of the communications and information systems so as not to
compromise availability. The sizing must be based on realistic estimates of
demand for the e-Government service.
131 For example, use of multi-tier, high redundancy architectures (eg redundant processor configurations,
mirrored disks, RAID arrays etc) and geographical distribution
10.8.3 UPS must be used to al ow `soft' failure. Power recovery must be
achievable within the timescale appropriate to the business need at Availability
IL3.
10.8.4 Alternative communications paths that can be switched in within the
timescale appropriate to the business need at Availability IL3 must be available.
It is anticipated that at this level alternative communications paths with immediate
failover wil be required.
10.8.5 A configuration management plan and processes covering the
communications and information systems providing the service must be designed
and implemented. Operational and security configuration must be checked for
compliance with documentation, supplemented by a CHECK process.
Configuration changes must be approved by the service manager before
implementation and must be subject to secure audit (technical or procedural).
Software must only be introduced with the approval of the service manager and a
ful inventory of al hardware and software and a network diagram showing al
approved connections must be maintained.
10.8.6 Failure impact analysis must be carried out and recorded for al
information and communications components. This must be reviewed in the
event of significant configuration changes. No upgrades wil be permitted without
prior offline testing and assessment.
10.8.7 A commercial best practice self-test process should be in place.
10.8.8 A business continuity plan should be in place and subject to regular
review. The business continuity plan should be subject to regular rehearsal. The
plan should address: management roles and responsibilities for business
continuity; recovery procedures and audit trail, covering the system,
communications and transactions; security specific recovery actions.
Information availability
10.8.9 It is required to identify and recover partial y complete transactions that
might have failed in the event of non-malicious failure and to inform the parties
involved accordingly.
10.8.10 Information back up must enable restoration of al relevant information to
within one day of the current data, and preferably more regularly than this.
Commercial best practice must be fol owed with a ful weekly backup and daily
incremental backups, preferably supported by a continual backup process. The
backup must be compared against the original before the backup media is stored
offsite. The restoration process must be documented in the business continuity
plan and tested regularly.
10.8.11 Baseline level cryptographic checksums or secure software isolation for
system software, configuration data and storage facilities must be provided. A
secure self-test process must be undertaken regularly using these facilities.
10.8.12 A process must be available to provide access for a client to his/her
client account in the event of loss of an access token.
11 Worked examples
11.1 General
11.1.1 This section provides some worked examples to demonstrate the
application of the method set out within this document. These services are purely
hypothetical and are not intended to bear any relation to specific real-world
services in current operation.
11.1.2 The worked examples have been deliberately simplified and presented at
an overview level of detail to aid clarity.
11.2 Hypothetical pseudonymous medical screening service
STEP 1: define the service
Purpose
11.2.1 A pseudonymous medical screening service132 al owing clients to register
for health screening, and receive their test results, electronical y. Client
requirements
11.2.2 The high-level actions that a client may wish to conduct in support of this
service may include the fol owing:
- find out information about the service electronical y;
- book an appointment electronical y;
- be contacted electronical y to obtain the test results;
11.2.3 Other features that a client might require include the fol owing:
- be able to obtain the service under a pseudonym, and not reveal any details
of their real-world identity to the service;
- have confidence that they are receiving the correct test results;
- have their test results kept confidential. Service requirements
11.2.4 The high-level requirements for the service are as fol ows:
- no level of assurance is required in the clients real-world identity;
- the eligibility of a client does not need to be established, as the service is
freely available;
132 This example assumes that the service is screening for non-life-threatening diseases.
- a persistent electronic identity for the client is required, which provides a
substantial degree of assurance to the e-Government service that it is the same
client returning;
- evidence that the client actual y received and has read any communications
(if they did so).
[Table 8 and Fig 8 deleted]
11.2.5 The major attack groups and compromise paths that pose a threat to this
service, and the compromise paths that could be exploited, are assessed to be
accidental and deliberate compromise by authorised users, and access control
and network attacks by private investigators and inquisitive
organisations/individuals.
11.2.6 It is considered unlikely that foreign intel igence services or terrorists pose
a threat to this service. The attack groups and compromise paths identified here
are within the remit of the standard groups identified at Section 4 of this
document; therefore there is no requirement to apply HMG IS1 in addition to this
guidance.
STEP 2: define impact levels for each service characteristic
11.2.7 Impact levels133 must be assigned to each relevant service characteristic
for each transaction a service supports,134 and for the information that it stores.
11.2.8 Table 9 sets out the impact levels for each of the transactions
representing information exchange between clients and the e-Government
service.135 Transactions attract impact levels for each of identity registration,
enrolment, client authentication, confidentiality, integrity and availability. Three
groups of transactions have been identified for this service:
- Set A: provision of information by a client to the government service;
- Set B: provision of information from the government service to a client;
- Set C: provision of test results from the government service to a client.
[Table 9 deleted]
133 Defined by the HMG Impact Table, and reproduced in part at Annex D of this document. 134 As defined
in the description of the service provision environment at . Table 8135 The relevant definition within the HMG
Impact Table is referred to in each instance (for example, definition C1: public services, risk to life and
safety).
11.2.9 Table 10 sets out the impact levels for compromise of information stored
within the service provision domain.135 Information assets attract impact levels for
confidentiality, integrity and availability only. Identity registration, enrolment and
authentication are mechanisms which support the transactions by which
information assets are managed, rather than the information assets themselves,
so do not need to be considered here.
[Tables 10 & 11]
11.2.11 In this example, it is considered to be appropriate to protect the
information to the high-water mark of both of the impact levels attracted to the
transactions and of the information assets, and to define a single set of impact
levels within the entire service.
STEP 3: apply standard minimum countermeasures
11.2.12 The standard minimum countermeasures and considerations set out at
Section 2 (Step 3), and those set out in support of each of the service
characteristic (Sections 5-10), should be implemented.
11.2.13 Although both identity registration and enrolment attract IL0 for this
service, particular consideration must be given to management of the distribution
of electronic credentials to clients which wil be determined by the impact level
attracted to client authentication.
STEP 4: apply transaction-specific countermeasures
11.2.14 The specific countermeasures to be put in place for this service are
dependant on the impacts identified for each service characteristic at Step 2. In
this example, the countermeasures are service-specific as opposed to
transaction-specific because a single set of impact levels were defined for the
entire service.
11.2.15 The countermeasures required at the range of impact levels calculated
for each service characteristic are outlined at Sections 5-10. The actual choice of
countermeasures needs to be considered in terms of risk to the service as a
whole, cost of implementation, practicality and overal business benefit.
11.2.16 For this service, specific consideration must be given to the requirements
evidence of receipt within the countermeasures for integrity (IL2). One workable
solution in this case would be to manage evidence-of-receipt as a back-end
function, requiring the client to log on to the service to receive their results, and
treating access of these results as an accountable event.
STEP 5: agree, document and implement risk management decisions
11.2.17 The procedures to be implemented includes, for example:
- clearly documenting risk management and risk assessment decisions in the
RMADS, which wil be updated as required;
- a regular IA review (a six-monthly or annual review cycle would probably be
appropriate in this case) throughout the lifetime of the service, and as required in
exceptional circumstances;
- documenting policy on what compromises and losses are acceptable (eg no
client should receive inaccurate test results through a loss of integrity of the IS).
11.3 Hypothetical tax return service
STEP 1: define the service
Purpose 11.3.1 A service al owing an individual citizen to file a personal self-
assessment tax return electronical y.
Client requirements
11.3.2 The high-level actions that a client might wish to conduct in support of this
service include the fol owing:
- electronical y access information about completing a tax return, for example,
the information that is required and the telephone number of a help desk;
- complete and submit their tax form electronical y in more than one sitting if
required;
- be able to access an online account detailing payment history and any
outstanding balances.
11.3.3 Other features that a client might require include the fol owing:
- delegate another person or organisation, for example an accountant, to
complete and submit a tax return on their behalf;
- have any information provided kept confidential;
- have the integrity of the information they submit preserved;
- reveal only the identity information necessary to complete the transaction;
- be electronical y notified of any tax owed to/by them;
- be provided with an acknowledgement that their form has been received;
- be able to file a tax return whenever is convenient for them;
- have their tax worked out automatical y as they complete the form, so that
they know what they owe or are owed straight away;
<li>be provided with an acknowledgement that any tax paid by them is received
by the service. Service requirements
11.3.4 The high-level requirements for the service include:
- a substantial level of assurance in the client's real-world identity (eg name,
residency);
- a low level of assurance that a client is eligible to receive the service, as it is
freely available to al citizens who pay tax in the UK;139
- a client to have a persistent electronic identity, of which it can have
substantial level of assurance that it is the same client returning;
- the details required to calculate their tax (eg details of a client's employment,
income, bank accounts, savings and investments) to be provided by a client as
part of the service;
- acknowledgement that any tax paid by the service is received by the client;
- maintenance of up-to-date personal details by the client.
[Table 12 deleted]
11.3.5 The major attack groups that pose a threat to this service, and
compromise paths that could be exploited, are assessed to be individual
fraudsters, organised criminal groups and hackers.
11.3.6 Individual fraudsters and organised criminal groups are most likely to
exploit the service for their own gain, for example by misappropriating genuine
real-world identities or simply misusing their own real-world identity to claim back
tax which they are not entitled to receive. Hackers, however, are most likely to be
testing their abilities or cause disruption to the service by utilising network attacks
and access control attacks.
11.3.7 It is considered unlikely that foreign intel igence services or terrorists pose
a threat to this service. However, consideration must be given to the amount and
type of information directly connected to the service; in aggregation particular
information may be attractive to these attack groups.
11.3.8 The attack groups and compromise paths identified here are within the
remit of the standard groups identified at Section 4 of this document; therefore
there is no requirement to apply HMG IS1 in addition to this guidance.
STEP 2: define impact levels for each service characteristic
11.3.9 Impact levels140 must be assigned to each relevant service characteristic
for each transaction a service supports,141 and for the information that it stores.
11.3.10 Table 13 sets out the impact levels for each of the transactions
representing information exchange between clients and the e-Government
service.142 Transactions attract impact levels for each of identity registration,
enrolment, client authentication, confidentiality, integrity and availability. Four
groups of transactions have been identified for this service: - Set A: provision of
information by a client to the government service; - Set B: provision of
information from the government service to a client; - Set C: transfer of money
from the government service to a client; - Set D: transfer of money from a client
to the government service. 140 Defined by the HMG Impact Table, and reproduced in part at Annex
D of this document. 141 As defined in the description of the service provision environment
143 This is assumed to be the general case, although there wil be exceptions where a client's tax return is
greater than the values stated here.
[Table 13 deleted]
11.3.11 Table 14 sets out the impact levels for compromise of information stored
within the service provision domain.142 Information assets attract impact levels for
confidentiality, integrity and availability only. Identity registration, enrolment and
authentication are mechanisms which support the transactions by which
information assets are managed, rather than the information assets themselves,
so do not need to be considered here. [Table 14 deleted]
11.3.12 Table 15 displays the range of impact levels which have been assigned
to each service characteristic both for transactions and for the information assets.
[Table 15 deleted]
11.3.13 The aggregation of information within the service provision domain
results in a requirement for more stringent mechanisms to protect the
confidentiality of the information assets than is required to protect the
confidentiality of information in transit between a client and the e-Government
service.
11.3.14 In this case it is not considered appropriate to assign one set of impact
levels for the entire service, as this would rest in high costs for implementing
countermeasures at Confidentiality IL3, and may inhibit the functioning of the
service. Therefore, one set of impact levels are assigned for the transactions,
and another set for the information assets.
STEP 3: apply standard minimum countermeasures
11.3.15 The standard minimum countermeasures and considerations set out at
Section 2 (Step 3), and those set out in support of each of the service
characteristic (Sections 5-10), should be implemented.
11.3.16 Although this service attracts Enrolment IL0, particular consideration
must be given to the balance of responsibilities between this service and the
Government Gateway. This is particularly applicable to the management of the
distribution of electronic credentials to clients which wil be determined by the
impact level attracted to client authentication.
STEP 4: apply transaction-specific countermeasures
11.3.17 The specific countermeasures to be put in place for this service are
dependant on the impacts identified at Step 2. In this example, the
countermeasures required to protect information in transit are set by the high-
water mark of the impact levels attracted to transaction sets A-D. The
countermeasures required
11.3.18 In this example, the countermeasures are specific to the transactions as
a whole, and to the information assets (which require more stringent
countermeasures to protect the confidentiality of the information).
11.3.19 The countermeasures required at the range of impact levels calculated
for each service characteristic are outlined at Sections 5-10. The actual choice of
countermeasures needs to be considered in terms of risk to the service as a
whole, cost of implementation, practicality and overal business benefit.
11.3.20 It may not practical for the service to implement the countermeasures
required at Availability IL3 (for both the information assets and the transactions).
In such instances, a risk-balance-decision could been taken to reduce Availability
IL3 to Availability IL2, for example by introducing a caveat stating that if the
electronic service is not available, the deadline wil be extended as necessary so
that a tax return can be completed by other channels (eg postal).
11.3.21 When applying countermeasures, particular consideration must be given
to:
- whether or not the Government Gateway meets the requirements of the
service for identity registration, enrolment and authentication (the Government
Gateway issues a client's electronic credentials). The Government Gateway is a
Registration IL2 and Authentication IL2 service, so in this example it meets the
requirements of the service;
- the management of information exchange between the Government Gateway
and the service relating to a client's personal information (eg ensuring that details
of a client's address are kept current);
- the requirements for both non-repudiation and evidence of receipt. For
example, some of the non-repudiation requirements could be met by al owing a
client to view a record of their transactions with the e-Government service on
once they have authenticated themselves to the service.
STEP 5: agree, document and implement risk management decisions
11.3.22 Al risk management and risk assessment decisions should be clearly
documented in the RMADS (particularly the decision to implement availability IL2
countermeasures instead of IL3). This service should undergo regular IA reviews
throughout its lifetime, and as required in exceptional circumstances, with the
RMADS being updated in-line with the reviews.
11.3.23 Examples of other procedures to be implemented include documenting
policy on what compromises and losses are acceptable, for example, the
acceptable downtime of this service should be clearly set out, with particular
consideration being given to times when the deadline for submission of tax
returns is imminent.
11.4 Hypothetical disabled parking permit service
STEP 1: define the service
Purpose
11.4.1 This service al ows clients with disabilities to apply electronical y to their
local government authority for a parking permit.144 Client requirements
11.4.2 The high-level actions that a client may wish to conduct in support of this
service may include the fol owing:
- apply for a parking permit electronical y, or delegate another person to apply
for the parking permit in their name;
- have their eligibility to receive a parking permit established electronical y, with
as little requirement as possible to provide evidence off-line;
- renew their permit electronical y;
- be able to update their personal information as required.
11.4.3 Other features that a client might require include the fol owing:
- being able to use their parking permit as either a driver or a passenger;
- have their eligibility established correctly;
- reveal only the minimum identity information required to obtain this service;
- have any personal information stored or transmitted kept confidential. Service
requirements
11.4.4 The high-level requirements for the service are as fol ows:
- a substantial level of assurance in the client's real-world identity (eg proof of
name, residency, age and photographic identification);
- delegates are required to state their relationship to the client, and their
entitlement to act as the client's delegate (this may require the service to contact
a client to verify their entitlement);
- when applicable, appropriate assurance that a client has given authorisation
to a delegate to apply for a permit on the client's behalf;
- a high level of assurance in the client's eligibility to receive this service (eg
proof of any disability or disability al owances received, provision of doctor's
details and consent to contact);
- the ability to link the apparent originator of an electronic transaction with a
real-world identity;
- a persistent electronic identity to be established, of which the e-Government
service can have a substantial degree of assurance that it is the same client
returning.
144 A parking permit in this example is defined as a national arrangement of on-street parking concessions
enabling people with disabilities to park close to their destination.
[Table 16 & Fig 10 deleted]
11.4.5 The major threat posed to this service is assessed to be deliberate
compromise by individual fraudsters and organised criminal groups who might
create false identities, or misappropriate genuine real-world identities to claim a
parking permit that they are not entitled to. Organised criminal groups may sel
have a motivation to sel on parking permits on for profit.
11.4.6 An additional channel that may also be exploited is citizens applying
fraudulently for the higher rate of DLA from the DWP as this al ows automatic
qualification for a disabled parking permit. It should be noted that this may
particularly be the case in inner city areas where parking is at a premium,
although as it is a national scheme, the threat should be considered in al areas.
11.4.7 It is considered unlikely that foreign intel igence services or terrorists pose
a threat to this service. The attack groups and compromise paths identified here
are within the remit of the standard groups identified at Section 4 of this
document; therefore there is no requirement to apply HMG IS1 in addition to this
guidance.
145 It should be noted that the definition of a transaction within this guidance includes only those exchanges
between a client and an e-Government service. For exchanges between the e-Government service and
trusted third parties, for example with the DWP to confirm that a client receives the highest rate of DLA, the
amount of trust placed in the third party should be assessed. Establishing trust in third parties may be aided
by use of a trust service approval scheme. 146 This does not include provision of the actual parking permit to
a client which would be sent by post to the client's home address.
STEP 2: define impact levels for each service characteristic
11.4.8 Impact levels147 must be assigned to each relevant service characteristic
for each transaction a service supports,148 and for the information that it stores.
11.4.9 Table 17 sets out the impact levels for each of the transactions
representing information exchange between clients and the e-Government
service.149 Transactions attract impact levels for each of identity registration,
enrolment, client authentication, confidentiality, integrity and availability. Two
groups of transactions have been identified for this service:
<li>Set A: provision of information by a client to the government service;
- Set B: provision of the information from the government service to a client;
[Table 17 and 17-2 deleted]
147 Defined by the HMG Impact Table, and reproduced in part at Annex D of this document. 148 As defined
in the description of the service provision environment at . Table 16149 The relevant definition within the
HMG Impact Table is referred to in each instance (for example, definition C1: public services, risk to life and
safety).
11.4.10 Table 18 sets out the impact levels for compromise of information stored
within the service provision domain.149 Information assets attract impact levels for
confidentiality, integrity and availability only. Identity registration, enrolment and
authentication are mechanisms which support the transactions by which
information assets are managed, rather than the information assets themselves,
so do not need to be considered here. 150 It should be noted that if a client is automatically
eligible for a parking permit because they are eligible for the highest rate of DLA from the DWP, the impact
level for integrity will only be as high as the integrity of the information received from the DWP.
[Table 18 deleted]
11.4.11 Table 19 displays the range of impact levels which have been assigned
to each service characteristic for both transactions and for information assets.
[Table 19 deleted]
11.4.12 In this example, to achieve optimum functionality of the service, it is
considered to be appropriate to protect the information (both in transit and within
the service provision domain) to the high-water mark, and to define a single set
of impact levels within the entire service.
STEP 3: apply standard minimum countermeasures
11.4.13 The standard minimum countermeasures and considerations set out at
Section 2 (Step 3), and those set out in support of each of the service
characteristic (Sections 5-10), should be implemented.
11.4.14 It should be noted that although the electronic transactions within this
service have little requirement for evidence of receipt, postal delivery of the
permits to a client wil have a requirement for evidence of receipt to ensure that the permit
has not been misappropriated in transit.
STEP 4: apply transaction-specific countermeasures
11.4.15 The specific countermeasures to be put in place for this service are
dependant on the impacts identified for each service characteristic at Step 2. In
this example, the countermeasures are service-specific as opposed to
transaction-specific, because a single set of impact levels were defined for the
entire service.
11.4.16 The countermeasures required at the range of impact levels calculated
for each service characteristic are outlined at Sections 5-10. The actual choice of
countermeasures needs to be considered in terms of risk to the service as a
whole, cost of implementation, practicality and overal business benefit.
11.4.17 Of particular consideration for this service is the requirement to conduct
as much of the service electronical y as is practicable. This particularly applies to
the provision of evidence for identity registration and enrolment:
- Examples of acceptable remote and online evidence at this impact level for
registration are provided at Annex E. For example, this service could make use
of the IPS passport checking service (provided a client held a valid passport), or
identity verification services for the identity registration of a client.
- Automatic enrolment requires a client to receive the highest rate of DLA from
the DWP. A client could provide evidence of this al owance by post; any other
methods (remote or online) must be commensurate with this. Online verification
could be carried out in liaison with the DWP by communicating the relevant data
across secure channels, subject to establishing appropriate trust relationship and
putting appropriate measures into place to support obligations under the DPA.
- Discretionary enrolment requires a client to provide a variety of evidence to
support their claim for a parking permit. Evidence can be presented face-to-face
at one-stop-shops; any other methods (remote or online) must be commensurate
with this. For example, this could be achieved by communicating data between
departments (subject to obligations under the DPA), checking databases or
telephone/email communication by government users. 11.4.18 Particular
consideration should also be given for the management of delegate accounts,
and the requirements for providing evidence of a delegate's entitlement to act on
a client's behalf.
STEP 5: agree, document and implement risk management decisions
11.4.19 Al risk management and risk assessment decisions should be clearly
documented in the RMADS at a basic level of detail. Particular consideration
should be given to management of the trust relationship with the DWP.
11.4.20 Other procedures to be implemented include conducting regular IA
reviews (an annual review cycle would probably be appropriate in this case)
throughout the lifetime of the service, and as required in exceptional
circumstances. The RMADS should be updated in-line with any reviews.
A Glossary
A.1
General A.1.1 Differences in the use of IA terminology can lead to incorrect
and/or inconsistent interpretation and implementation of IA policy and guidance.
This in turn can lead to a lack of mutual trust between organisations and other
problems with interoperability and joint working. A.1.2 This glossary defines the
terms used within this document. The approach taken has been, where possible,
to avoid the use of contentious terms and to align with the terminology set out by
the fol owing relevant references:
- HMG definitions as set out within HMG Infosec Standard No. 2 (HMG IS2)151,
which defines the risk management and accreditation process;
- Home Office (HO) definitions as set out within the Identity and Passport
Service (IPS) Identity Management Practitioners' Guide; the IPS glossary is
regarded to be the definitive set of definitions covering identity management
within government.
- HM Treasury (HMT) definitions as set out within the HMT Orange Book,152
which sets out the current position of HMT on risk management and is aligned
with Office of Government Commerce (OGC) guidance;
A.2 Glossary Access controls A.2.1 An access control is a measure to ensure
that elements of a service may only be accessed by suitably authorised users
and to ensure that transactions may only be conducted by suitably authorised
clients.
Access token
A.2.2 An access token is a (physical) medium that contains a credential. This
might be, for example, a smartcard that contains a digital certificate or biometric
information.
Account activation
A.2.3 Activation of a client account wil often be required to confirm that the
address (postal or electronic) the client account and electronic identity have been
sent to can be linked to the identity of the client. For example, this might be
achieved by the e-Government service sending a client an email which is
subsequently acknowledged by the client.
151 HMG Infosec Standard Number 2: risk management and accreditation of information systems, dated
July 2005. This document may be downloaded from the NISCC web-site, http://www.niscc.gov.uk. 152 The
Orange Book: management of risk principles and concepts, dated October 2004. This document may be
downloaded from the HMT web-site, http://www.hm-treasury.gov.uk.
Accreditation
A.2.4 Accreditation is the formal assessment of an information system or a set of
capabilities153 against the IA requirements of the information assets of that
information system or capability set. A.2.5 The accreditation process provides
evidence that an appropriate set of measures are in place to ensure an
acceptable level of risk for the confidentiality, integrity and availability of
information assets that are stored and handled within the accreditation boundary.
A.2.6 The impact levels for a compromise of the confidentiality, integrity and
availability of information assets are determined by the SIRO. For e-Government
services, impact levels for a compromise of the identity registration, enrolment
and authentication processes that support the service must also be determined.
The impact levels should be determined in consultation with the Accreditor,
supported by a ful risk assessment to set out the business impacts of
compromise. Important factors in determining the countermeasures that must be
in place and the level of residual risk to accept for information assets include the
residual risk that the risk owner is prepared to accept, and any prerequisite
requirements for envisaged onward connections.154
Accreditation boundary
A.2.7 The accreditation boundary represents the boundary between the elements
of an e-Government service that the SRO is responsible for and those things
over which the SRO has no direct control. The accreditation boundary often
corresponds to the boundary that is defined by an information system or a set of
capabilities. There wil frequently be connections that cross the accreditation
boundary, such as a network connection between a system being accredited and
the Internet.
Accreditor
A.2.8 An accreditor is the individual responsible for conducting the formal
assessment of an information system or a set of capabilities and for advising the
SIRO on the risks to information assets.
153 Such a capability-set might be hosted on a stand-alone infrastructure, on a common infrastructure within
an organisation, or on a pan-organisational infrastructure. It is anticipated that the latter two of these options
wil become increasingly prevalent across government, as part of the shift towards improved interoperability
and joint working and to al ow economies of scale to be realised. 154 Baseline IA requirements to connect to
a specific external system or network such as Government Secure Intranet (GSi) would be set out within the
Code of Connection for that system or network. Baseline IA requirements for connection to a different
capability set that is hosted on a common infrastructure would be set out within the Interconnection Security
Measures (ISM) for that capability set.
e-Government framework for Information Assurance Draft 5.1 Page 119
Anonymous client
A.2.9 An anonymous client is one who does not reveal their real-world identity
nor establish a persistent electronic identity prior to authorising a specific
transaction.
A.2.10 See the definition of pseudonymous client for comparison.
Attack group
A.2.11 An attack group is a group of one or more potential attackers (also known
as threat actors), who may be either unauthorised or authorised users of a
service.
A.2.12 Within the risk assessment method that is adopted here, attack groups
are defined in terms of the information assets that they are authorised to access,
their capability and their motivation.
Authentication
A.2.13 Authentication is the process by which a credential and col ateral
information are presented and verified, to establish a claim to a valid electronic
identity. An electronic identity to support authentication by a client would typical y
be provided during the identity registration and/or enrolment process. A.2.14 See
also service authentication and client authentication.
Authorisation
A.2.15 Authorisation is the process of determining which activities and access
are permitted to a client. Within a session, a client may request authorisation to
carry out further activities, which may require further authentication of the client
to the service.
Availability
A.2.16 Availability is defined as the ability for authorised users to access and use
information assets and services when required.
A.2.17 The risk assessment method that is adopted here defines information
assets in terms of the value of their confidentiality, integrity and availability.
Back-office system
A.2.18 A back-office system is the computer system within a government
department, agency, local or regional authority or other service provider, which
completes a requested service based on data provided.
Business impact of compromise
A.2.19 The business impact of compromise is the measure of the damage that
would be caused by compromise of the confidentiality, integrity and availability of
the information assets within a service.
A.2.20 The risk assessment method that is adopted here measures the business
impact of compromise on a four-point scale of impact levels, from Impact Level 0
(IL0) through to Impact Level 3 (IL3).
CAPS
A.2.21 The CESG Assisted Products Scheme (CAPS)155 supports the
commercial development of cryptographic products for Government
requirements. It is aimed at supporting those applications where commercial-
grade cryptography is required in a government environment. Assessments of
those products submitted to the scheme are carried out by CESG in house, and
result in a fit-for-government use certificate being awarded if successful.
CCT Mark
A.2.22 The CSIA Claims Tested (CCT)156 Mark scheme is a Government
sponsored assurance scheme which, through accredited independent testing,
provides the public sector with confidence in the claims made by Vendors about
the functionality of their information security products and services.
A.2.23 The scheme provides a basic level of assurance (equivalent to EAL1) to
these products and services, and wil give confidence to purchasers that the
Vendor's security functionality claims have been validated.
A.2.24 The scheme is aimed primarily at those products and services which may
be purchased by central government and the wider public sector, particularly the
NHS, Education, Local Authorities and Criminal Justice.
Challenge-response
A.2.25 Chal enge-response is the mechanism that is typical y used to test
whether the recipient of the chal enge can be authenticated for a particular
service.
CHECK
A.2.26 The CESG IT health check service (CHECK) was developed to enhance
the availability and quality for the IT health check service that are provided to
government service providers across central government departments, wider
public sector organisations and elements of the Critical National Infrastructure
(CNI), in line with HMG policy.
155 Further details about the CESG Assisted Products Scheme can be found at http://www.cesg.gov.uk. 156
Further details about the CSIA Claims Tested Mark scheme can be found at the Cabinet Office web-site,
http://www.cabinetoffice.gov.uk/.
Client
A.2.27 The term client is used here to denote a person or organisation, a
delegate of a person or organisation, or an element of another service seeking to
carry out a transaction using an e-Government service.
Client authentication
A.2.28 Client authentication is the process by which a client presents a credential
and col ateral information, which is checked by or on behalf of an e-Government
service to verify the electronic identity of the client and the entitlement of the
client to receive the service or conduct the transaction requested.
A.2.29 See also authentication and service authentication.
Common criteria
A.2.30 The Common Criteria157 (CC) are the outcome of efforts to develop criteria
for the evaluation of IT security that are widely useful within the international
community. It is an alignment and development of a number of existing
European, US and Canadian criteria (ITSEC, TCSEC and CTCPEC
respectively). It is a contribution to the development of an international
standard158, and opens the way to worldwide mutual recognition of evaluation
results.
A.2.31 The Common Criteria present requirements for the IT security of a
product or system under the distinct categories of functional requirements and
assurance requirements. The CC functional requirements define the desired
security behaviour, and the assurance requirements are the basis for gaining
confidence that the claimed security measures are effective and implemented
correctly.
A.2.32 While it is not precluded that e-Government systems undergo a CC
evaluation, this may not be suited to a dynamic environment with fast changing
systems and products. However, system implementers may wish to use
previously evaluated products within their systems. These products wil have
been submitted by their developers to an independent security assessor for
evaluation against a particular Target of Evaluation (ToE). The extent to which
the ToE covers how the product is to be used in any particular system should
always be borne in mind.
Compromise path
A.2.33 A compromise path is the means by which an attack group could
compromise the confidentiality, integrity or availability of an information asset.
Examples
157 Further details of the Common Criteria and those products already evaluated can be found on the CESG
web-site, http://www.cesg.gov.uk/. 158 The Common Criteria have been adopted as an International
Standard (ISO IS 15408).
include network attacks, access control attacks and passive interception attacks.
The definition used within this document also includes accidental and deliberate
compromise by authorised users as compromise paths.
Concern A.2.34 A concern represents the mapping between an attack group and
a business (sub-)domain, for example covering "compromise of (sub-)domain by attack group x".
A.2.35 For each concern, a separate risk level is identified for each of the
confidentiality, integrity and availability of the information assets within the
relevant (sub-)domain and for each identified compromise path.
Confidentiality - A.2.36 Confidentiality is defined as the ability to ensure that
information is only accessed by or disclosed to authorised users. A.2.37 The risk
assessment method that is adopted here defines information assets in terms of
the value of their confidentiality, integrity and availability.
Credential
A.2.38 A credential is a set of information which is employed to establish an electronic
identity as part of the authentication process. A credential may be associated
with col ateral information supporting a client's right to possess that credential
(such as a PIN or private signing key).
Credential issuer
A.2.39 A credential issuer issues, manages and revokes credentials.159
Credential revocation list
A.2.40 A credential revocation list is a list of credentials that have been
withdrawn prior to their normal expiry date.160
Delegate A.2.41 A delegate (also referred to as a proxy) is an intermediary that
has been authorised to conduct a specified set or range of transactions on behalf
of an e-Government client. This might include, for example, an accountant or
other professional acting on behalf of a specified person or organisation, a legal
guardian, or a person acting under a power of attorney on behalf of a relative or
patient.
159 One example of a credential issuer is a certification authority, which issues, manages and revokes digital
certificates at the request of an RA. 160 One example of a credential revocation list is a certificate revocation
list.
A.2.42 In some cases a delegate would be entitled to perform any transaction
offered by a service for the client on whose behalf they act. More general y, a
delegate would be authorised to perform some wel -defined subset of the
activities that the client they represent is able to perform (for example, an
accountant might be authorised to complete a client's tax returns, but might not
be authorised to change that client's address details).
Deterrence
A.2.43 Deterrence is the concept that the likelihood of an attack can be reduced
if the attack group fears punishment, or some other negative consequence, if
detected.
Directgov
A.2.44 As a brand, Directgov refers to the provision of government services by
electronic means. The service provider could be, for example, a central
government department, a government agency, a local authority or a private
sector organisation acting on behalf of local or central government. A.2.45 The
Directgov portal provides access to Directgov services, bringing together a wide
range of public service information and services online.
Disenrolment
A.2.46 Disenrolment is the process by which a client's right to a particular service
is removed.
e-Government service
A.2.47 An e-Government service is a service that is provided by government or
agents of government, to members of the public, delegates or voluntary sector
organisations, which is supported by transactions via an electronic delivery
channel such as the internet.
A.2.48 This loose definition covers a very wide range of applications, including:
- passive web services that al ow information retrieval from a departmental
web site, or from multiple departmental assets (eg information on business travel
overseas from the Foreign and Commonwealth Office (FCO) and Department of
Trade and Industry (DTI));
- interactive services that enable information exchange with an individual
government department (eg applying for a grant or licence) or with multiple
government departments (eg notification and receipt of confirmation of a change
of address);
- private correspondence with Government officials where some level of trust
(traceability and accountability) is required of the information exchanged and in
the electronic media of communication;
- complex multi-function services that enable both passive and interactive
interaction with multiple departmental assets. For example citizens might access
`joinedup' services via a single web portal that logs their query, and identifies
and notifies the relevant government departments via e-mail.
Electronic identity
A.2.49 An electronic identity is a set of information that uniquely identifies a client
to an electronic service or vice versa. An electronic identity wil necessarily
correspond to one or more real-world identities (for example, a person or an
organisation, a representative of a person or organisation, a service or a
process), but the real-world identity need only be revealed if it is necessary for
the transaction.
A.2.50 The electronic identity of a client would typical y be comprised of some or
al of the fol owing:
- something that the client knows, such as a username and/or a password;
- something that the client has, such as a digital certificate, biometric or other
token;
- elements that tie the client's electronic identity to their real-world identity,
such as a National Insurance Number (NINO), passport number, NHS number or
other identifier.
Enrolment
A.2.51 Enrolment is the process by which a client is enabled access to a specific
e-Government service. Enrolment is concerned with establishing the entitlement
of a client to receive an e-Government service (eg whether that client is eligible
for tax credits). Identity registration, by comparison, is concerned solely with
verifying the identity of a client. Before being enrol ed a client might first register
their real-world identity to an appropriate level of assurance, or a pseudonym,
with the service provider or a trusted third-party.
A.2.52 Successful enrolment of a client wil include provision of an account for
that client. Enrolment might also include provision of an electronic identity for that
client or might make use of an electronic identity that was issued during the
identity registration process. In some cases, use of an existing electronic identity
might require this to be extended.161 The strength of any authentication credential
provided during enrolment must be commensurate with the impact level attracted
to client authentication.
A.2.53 A client must enrol at or before first use of a service and may only use
those services for which they are enrol ed. Evidence requirements for enrolment
wil depend on the details of the service to be used and must be set in
conjunction with relying parties.
161 For example, by adding col ateral information to support that electronic identity.
Entitlement
A.2.54 Entitlement is the process of establishing a citizen's right to a service for
which they are trying to enrol.
Evidence of receipt
A.2.55 Evidence of receipt is the evidence provided by an e-Government service
that the intended recipient of an electronic communication or second party to a
transaction actual y received the communication (if they did so).
Fast track
A.2.56 The Fast Track Assessment Service162 was developed to address the
end-user requirement for significant improvements in the flexibility and efficiency
of the current evaluation process. The formal Infosec evaluation process under
the UK IT Security Evaluation and Certification Scheme (ITSEC) was designed to
incorporate a number of highly desirable features, including international y
recognised certificates of evaluation to objective standards, repeatability and
independent oversight. However, it has been recognised that not al the features
associated with formal evaluations are necessary to meet the assurance
requirements of sponsors in al cases.
A.2.57 The Fast Track Assessment Service defines a less formal evaluation
process that aims to achieve very significant cost and time savings compared to
the most formal evaluations, and be sufficiently widely applicable to be a
genuinely useful addition to the range of assurance options available.
A.2.58 In cases where it is felt that some assurance about a particular product is
required but there is no formal y evaluated equivalent available, then the Fast
Track process should be considered.
FIPS-140
A.2.59 The US Federal Information Processing Standard 140-2163 (FIPS PUB
140-2) provides a framework for the evaluation of cryptographic modules for use
in processing US unclassified material.
A.2.60 The standard was developed by US government and industry and
identified requirements for four security levels of cryptographic modules to
provide for a wide spectrum of data sensitivity, and a diversity of application
environments.
A.2.61 While the security requirements in the standard are intended to maintain
the security of a cryptographic module, conformance to the standard does not
guarantee that a particular module is secure. Similarly, the use of a 162 Further details
about the Fast Track Assessment process can be found at the CESG web-site, http://www.cesg.gov.uk. 163
Further details about FIPS PUB 140-2 can be found at the NIST web-site, http://www.nist.gov.
cryptographic module that conforms to this standard in an overal system does
not guarantee the security of the overal system.
A.2.62 If it is not practicable or appropriate for a CAPS evaluated product to be
used, then a FIPS-140 product, that provides the relevant level of security, may
be considered. NIST, the owners of the standard, license a number of
laboratories to provide conformance testing to the standard.
Government gateway
A.2.63 The government gateway is a specific example of an access system. It is
a hub linking portals and external back-office systems to government back-office
systems. Amongst other things, the gateway provides common security services,
including identity registration and authentication of clients. Once a client has
been authenticated, the government gateway forwards information between the
client and appropriate government back-office systems. It coordinates
transactions on government back-office systems on behalf of the client to support
`joined-up' government services. The government gateway also provides a
secure messaging facility to al ow government departments to communicate with
the client. The linkage between a portal and a government back-office system
may be asynchronous, or synchronous.
Government user
A.2.64 A government user in this context denotes a person or process that
interacts with an e-Government service (in any capacity) from within the e-
Government service provision boundary; this includes third parties involved in the
provision of e-Government services.
Identity registration
A.2.65 Identity registration is the process by which a client registers a
pseudonym, or registers their real-world identity to a desired level of assurance.
This may include presentation of evidence by the client as proof of their real-
world identity,164 and checks to ensure that the evidence provided is authentic,
valid and belongs to the client. The real-world identity of a client need only be
established if this is essential to support the service(s) to be provided.
A.2.66 Successful identity registration of a client might include provision of an
account and/or electronic identity for that client.
Identity verification
A.2.67 Identity verification is the process of checking a client's claimed real-world
identity to a desired level of assurance, by checking the evidence provided is
authentic, valid and belongs to the client.
164 For example, a driver's license or passport number.
Impact Levels
A.2.68 The business impact of compromise is measured here on a four-point
scale of impact, where Impact Level 0 (IL0) represents a negligible impact of
compromise and Impact Level 3 (IL3) represents a significant impact of
compromise. Depending on the range of clients to be supported by a service and
their differing service requirements and corresponding needs for identity
registration, enrolment and authentication, a service may consist of several
compartments, with each compartment supporting information assets with a
different set of impact levels.
Information asset
A.2.69 An information asset is any col ection of information, or any capability to
process and use that information, which is considered to have value to an
organisation, its business operations and its continuity.
Information Assurance
A.2.70 Information Assurance (IA) is the confidence that e-Government services
wil protect the information they handle and wil function as they need to, when
they need to, under the control of legitimate users.
Integrity
A.2.71 Integrity is defined as the accuracy, correctness and completeness of an
information asset. This requires confidence that the contents of a communication
or transaction as received by the recipient is the same as the communication
sent by the originator and could not have been modified, either deliberately or
accidental y, en route to the recipient. The definition of integrity that is adopted
here also encompasses non-repudiation.
A.2.72 The risk assessment method that is adopted here defines information
assets in terms of the value of their confidentiality, integrity and availability.
Network defence services
A.2.73 Network defence services are the technical means by which the threats
associated with connecting services electronical y may be countered. In the
current context, this refers primarily to ensuring that the e-Government service is
adequately protected against outside malicious electronic attack (and inadvertent
attack might have the same effects) intended to:
- undermine continued provision of a service; and/or
- affect adversely the integrity of services or information provided; and/or
<li>use the information resources of e-Government in the commission of serious
crime; and/or
- otherwise cause damage to government, systems or clients.
Non-repudiation
A.2.74 Non-repudiation is the ability to link the apparent originator of an
electronic transaction or communication with a real-world identity, such that the
originator cannot subsequently deny responsibility for that transaction or
communication.
A.2.75 Non-repudiation encompasses accountability (ie the extent to which the
issuer of an instruction can be held to account for that instruction), providence (ie
the extent to which users who are in receipt of information can act on that
information) and evidence of receipt. Some elements of non-repudiation,
particularly accountability and evidence of receipt, may need to be supported by
services such as record management and time-stamping in some cases.
A.2.76 In the risk assessment method that is adopted here, non-repudiation is
treated as a component of integrity.
Online identity registration
A.2.77 Online identity registration is a subset of remote identity registration which
involves the presentation and verification of evidence of a client's electronic
identity by purely electronic means.
Out-of-band
A.2.78 Out-of-band transactions occur via a communications channel other than
the normal means of communication with a service. For e-Government services,
this refers to communication via a channel other than the internet. Post,
telephone and SMS are al examples of out-of-band communications channels in
this context.
Provisioning
A.2.79 Provisioning is the process of providing a client with accounts, the
appropriate credentials and supporting information to access those accounts, al
rights associated with those accounts, and al of the resources necessary to
manage those accounts.
Pseudonymous client
A.2.80 A pseudonymous client is one who reveals only a pseudonym prior to
authentication for a specific service. A pseudonymous client establishes a
persistent electronic identity which can be recognised for repeat transactions but
does not reveal their real-world identity.
A.2.81 See the definition of anonymous client for comparison.
Public sector body
A.2.82 The term public sector body as used here has the meaning ascribed to it
by Regulation 3 of the Freedom of Information Act. A few examples of public
sector bodies are government departments, local authorities, police authorities
and NHS organisations, schools, col eges and universities, the police, the House
of Commons and the House of Lords, the Northern Ireland Assembly, the
National Assembly for Wales.
Real-world identity
A.2.83 A real-world identity is a set of attributes (eg name, date of birth, national
insurance number), which uniquely discriminates between clients. An entity can
possess only one real-world identity (eg a person or an organisation). However, a
single real-world identity may be used in conjunction with different roles and/or
support several electronic identities. Depending on the transaction, a client may
be required to reveal their real-world identity or may be permitted to use a
pseudonym or remain anonymous.
Receipt
A.2.84 A receipt provides evidence for a party in a transaction that can be used
at a later date to confirm that a specific element of the transaction has been
completed.
Registration authority
A.2.85 A Registration Authority (RA) is an organisation that verifies evidence
both that a real-world identity exists and that a client is entitled to use or
represent that real-world identity.
Remote identity registration
A.2.86 Remote registration of a client's identity involves presentation and
verification of that identity via electronic delivery mechanisms, or offline
mechanisms such as telephone or post.
Relying party
A.2.87 A relying party trusts a credential to associate an electronic identity with a
client. The relying party is often the organisation that is responsible for carrying
out the e-Government service, and hence relies upon a credential as part of
authorising a client.
A.2.88 Clients may also be relying parties if they rely on a government-issued
credential to assure themselves that they are real y dealing with the government.
Risk
A.2.89 A risk is the potential that a given threat wil exploit a compromise path to
compromise one or more information assets. If there is no business impact of
compromise, or no likelihood of the risk being realised, there is no risk.
Risk assessment
A.2.90 A risk assessment is an assessment of threats to, impact on and
vulnerabilities of information and information processes and the likelihood of their
occurrence.
Roles
A.2.91 A client may assume one or more roles in their interaction with
government. For example, a person may simultaneously be both an employee
and an employer. Similarly, government users may assume a number of roles in
their interaction with e-Government services.
Senior Information Risk Owner
A.2.92 The SIRO is an individual identified within each department as being
responsible for information risks and for influencing the board in managing these
risks properly.
Service authentication
A.2.93 Service authentication is the process by which an e-Government service
presents a credential and col ateral information to a client (eg an electronic
signature) which is checked by or on behalf of the client to verify165 the electronic
identity of the service.
A.2.94 See also authentication and client authentication.
Service provider
A.2.95 A service provider is an organisation responsible for the provision of a
specific e-Government service. The service provider might merely operate the
service using its own or government-owned equipment, or it might design and
develop the service.
A.2.96 The service provider must ensure that the service and relevant systems
are compliant with the e-government security framework, as required by the
SIRO and in conjunction with the Accreditor.
Threat
A.2.97 A threat is the level of danger posed to an information asset by an attack
group, based on the capability and motivation of that attack group to attack the
information asset (and modified by any deterrence and opportunity
considerations as appropriate). If there is no threat to an information asset, there
is no risk to that asset.
165 Verification of a service might be achieved by a client using a third-party certification authority such as
Verisign.
Transaction
A.2.98 A transaction is an exchange between two parties. The term transaction is
used specifical y here to represent an exchange between a client and an e-
Government service.
Trust service approval schemes
A.2.99 Trust service approval schemes provide assurance by developing sets of
criteria against which trust service providers can independently be assessed for
each of the trust services they wish to provide for clients. Trust service approval
is an essential element in providing a level of assurance to individuals and
companies using or relying upon e-government transactions.
A.2.100 The tScheme is one example of an independent, industry-led, trust
service approval scheme.
Trust services
A.2.101 Trust services are the means by which e-Government users (whether
government users or clients) can make commitments (binding166 or less formal)
electronical y, and if necessary, furnish the technical evidence to resolve any
dispute. In the context of this guidance, trust services must ensure that:
- transactions are demonstrably traceable to the originator (non-repudiation);
- transactions are demonstrably traceable to the recipient (evidence of receipt);
- commitments made using e-government services are not liable to fraud or
theft (trusted commitment service);
- information received from or passed via the e-Government services is not
altered or otherwise subverted (integrity).
Trust service providers
A.2.102 Trust service providers are those organisations that provide the means
to ensure confidence in e-Government services, such as Registration Authorities
(RAs), credential issuers and Certification Authorities (CAs).
Trusted commitment service
A.2.103 Trusted commitment service is ensuring that authorised clients of e-
Government services are confident that e-government services are not liable to
theft or fraud.
166 A binding commitment is typical y one where parties to the transaction are fulfilling statutory obligation or
there is a requirement to commit resources.
User A.2.104 The definition of user that is employed here includes both clients
and government users.
Verification
A.2.105 Verification is the process of confirming that someone (or something) is
who (or what) they claim to be.
Vulnerability
A.2.106 A vulnerability is a feature of a system which, if exploited by an attacker,
would enable the attacker to breach security.
B Related policy and guidance B.1 Identity management
B.1.1 The CSIA is the body responsible for the provision of guidance on IA
across government. However, the Home Office (HO), via the Identity and
Passport Service (IPS), is the lead department within government for identity
registration and management. The IPS is developing both strategic guidance on
identity management167 and also documentation to support IA practitioners.168
Where possible, this guidance has been developed in line with extant IPS
thinking. Close ties between CSIA and IPS wil be maintained to ensure that the
e-Government policy and guidance and IPS guidance remain aligned.
B.1.2 The European Identity Management (EID) Programme wil support a
coherent approach to identity management across Europe and aims to ease the
exchange of identity information as required between European government
organisations (for example, to manage the movement of individuals across
Europe to live and work, provision of medical treatment abroad, etc). The EID
programme is aligned with the IPS approach to identity management.
B.2 UK government guidance for IA
B.2.1 The MPS represents the minimum requirement for security management
for al central government departments and other organisations bound by the
MPS. The MPS and its supporting documents are aligned with the International
Organisation for Standardisation (ISO) 27000 series of standards, so that
adherence with MPS wil ease the route to ISO 27001 certification.
B.2.2 HMG IS2, HMG IS1 and the Infosec Manuals and Memoranda support
MPS by detailing the minimum requirements for IA, risk management and risk
assessment across al organisations bound by the MPS. HMG IS2 is aligned with
Office of Government Commerce (OGC) guidance on risk management.
B.3 International guidance for IA ISO 27000 series
B.3.1 The ISO 27000 series of documents provide a set of international
standards for the management of information security, which have been widely
adopted across Europe and the Commonwealth. These documents represent
commercial best practice for information security and include:
167 Cross-government identity management strategy (innovation and effectivenes), Mireille Levy. This
document is currently at Draft Version 0.14, dated 2 Oct 2006. 168 IPS identity management practitioners
guide, Martina Rydman and John Hughes. This document is currently at Draft Version 0.8, dated 1 Apr
2006.
<li>ISO 27000 technical vocabulary for IA;169
- ISO 27001:2005 information technology, security techniques, information
security management systems requirements;170
- ISO 27002 information technology, security techniques, code of practice for
information security management;171
- ISO 27003 information technology, security techniques, implementation
guidance;172
- ISO 27004 information technology, security techniques, information security
management metrics and measurement;173
- ISO 27005 information technology, security techniques, risk
management;174 National Institute of Standards and Technology
B.3.2 The American National Institute of Standards and Technology (NIST) has
adopted a similar approach to the UK Government for e-Government service
provision.175 Levels 1-4 as defined by NIST map broadly onto ILs 0-3 as defined
here. Similarly, the Australian e-Authentication Framework has adopted four
impact levels which map broadly onto ILs 0-3. The models for e-Government
service provision adopted by the Canadian and New Zealand governments are
based on open standards and ISO guidance. European Interoperability
Framework
B.3.3 The European Interoperability Framework (EIF) is a pan-European initiative
to improve communication between European member states and support the
delivery of pan-European e-Government services to businesses, citizens and
their delegates.
B.3.4 The high-level framework of the EIF176 provides 17 recommendations to
support EU interoperability, based around the principles of:
- accessibility of services;
- development of multilingual web-sites;
- consideration of security and privacy, promoting a PKI-based approach;
169 This document is currently in development. 170 This document is the replacement for BS7799 Part 2.
171 This document is due to be released in 2007 as a replacement for ISO 17799:2005, which in turn
replaces BS7799 Part 1. 172 This document is currently in development. 173 This document is currently in
development. 174 This document wil be the replacement for BS7799 Part 3. 175 Further details can be
found at the NIST web-site, http://www.nist.gov. 176 European Interoperability Framework for pan-European
e-Government services, Version 1.0, and other information on the EIF may be found at the Interoperable
Delivery of European e-Government Services to public Administrators, Businesses and Citizens (IDABC)
web-site, http://ec.europa.eu/idabc.
- use of open standards and open-source software wherever possible;
- use of interoperable middleware;
- use of common standards such as TCP/IP, HTTP, S/MIME, etc.
B.3.5 The EIF highlights a number of key interoperability areas for member
states, including public services for citizens and for businesses.
European Network and Information Security Agency
B.3.6 European Network and IS Agency (ENISA)177 is set up to provide advice,
analysis, awareness-raising and promotion of risk management methods and
maintains a directory of relevant bodies for European member states.
B.3.7 The work of the ENISA is currently at an initial stage of development.
Future iterations of this document wil need to be cognisant of ENISA initiatives.
B.4 Relevant legislation
B.4.1 The principal pieces of legislation that are likely to inform the IA
requirements for e-Government service implementations include and are not
limited to:
- the Human Rights Act and the underlying European Convention on Human
Rights set out everyone's right to privacy in their correspondence;
- the Data Protection Act178 sets requirements for the proper handling and
protection of personal information held within information processing systems;
- the Electronic Communications Act sets the requirements for electronic
signatures and their equivalence to conventional signatures;
- the Regulation of Investigatory Powers Act makes it an offence to
intercept communication on any public or private network; case and time limited
exemptions may be granted subject to warrant;
- the Terrorism Act makes it an offence to take actions which are designed
seriously to interfere with or seriously to disrupt an electronic system;
- the Wireless Telegraphy Act controls the monitoring of wireless telegraphy;
- the Police and Criminal Evidence Act defines conditions under which law
enforcement may obtain and use evidence;
- the Computer Misuse Act makes attempted of actual penetration or
subversion of computer systems a criminal act;
177 Further details can be found at http://www.enisa.eu.int. 178 The DPA and the eight data protection
principles that underpin it are summarised at Section 4.3.
- the Public Records Act lays down requirements for the proper care and
preservation of documentary records of government activities;
- the Official Secrets Act lays down requirements for the proper control of
government information;
- the Freedom of Information Act lays down the citizen's rights of access to
government held information.
C Service provision levels
C.1.1 The previous e-Government security framework documentation defined a
set of four service provision levels, layered according to the severity of
consequences that they might arise. These are set out in Table 20. These
service provision levels have subsequently been adopted and adapted by central
government, and correspond roughly to the definitions as set out in the HMG
Impact Level table, as reproduced in part at Annex D.
Severity of Consequences Appropriate e-Government Transactions Level 0 minimal inconvenience to
any party; no risk to any party's personal safety; minimal financial loss to any party; no damage to any
party's standing or reputation; no distress being caused to any party; no assistance in the commission of or
hindrance to the detection of serious crime. No private information content. Minimal damage might arise
from:
- failure to keep any commitments made;
- misappropriation of real-world identity;
- misappropriation of electronic identity (or no electronic identity is asserted);
- malicious electronic attack.
Level 1 minor inconvenience to any party; no risk to any party's personal safety; no release of personal y or
commercial y sensitive data to third parties; minor financial loss to any party; minor damage to any party's
standing or reputation; minor distress being caused to any party; no assistance in the commission of or
hindrance to the detection of serious crime. The information exchanged is client specific but the impact of
public exposure would be a minor resource or nuisance on one or more involved parties. Minor damage
might arise from:
- failure to keep any commitments made;
- misappropriation of real-world identity;
- misappropriation of electronic identity;
- malicious electronic attack.
Level 2 significant (moderate) inconvenience to any party; no risk to any party's personal safety; significant
(moderate) financial loss to any party; significant (moderate) damage to any party's standing or reputation;
significant (moderate) distress being caused to any party; assistance in the commission of or hindrance to
the detection of serious crime. Involving private information that could be regarded as sensitive. Significant
damage might arise from:
- failure to keep any commitments made;179
- misappropriation of real-world identity;
- misappropriation of electronic identity;
- malicious electronic attack. 179 This level would cover transactions of an official nature in which failure to
complete the transaction may be interpreted as a statutory infringement that may incur a penalty, or which
may have a significant impact on a third-party.
Level 3 substantial (significant) inconvenience to any party; risk to any party's personal safety; the release
of personal y or commercially sensitive data to third parties; substantial (significant) financial loss to any
party; substantial (significant) damage to any party's standing or reputation; substantial (significant) distress
being caused to any party; assistance in the commission of or hindrance to the detection of serious crime.
Involving private information that could be regarded as very sensitive. Substantial damage might arise from:
- failure to keep any commitments made;180
- misappropriation of real-world identity;
- misappropriation of electronic identity;
- malicious electronic attack.
Table 20: summary of previous service provision levels 180 This level would cover
transactions of an official nature in which failure to complete the transaction might have a substantial
financial impact (which might not be recoverable), or impact on the health or safety of instal ations or
individuals.
D HMG Impact Table D.1 Impact level definitions
D.1.1 The table that is spread across the fol owing two pages sets out the HMG
Impact Table definitions for IL0 through IL3, reproducing the segments of the
Impact Table that are relevant to e-Government service provision. These
definitions replace the set of four service provision levels as defined by the
previous e-Government security framework. The impact levels that are assigned
for e-Government services fol owing these definitions are expected to correspond
roughly (but not exactly) with the original definitions (as reproduced at Annex C).
D.1.2 The service characteristics for most e-Government services should be
subject to an impact level between IL0 and IL3. Where IA requirements exceed
these definitions, the ful impact level table covers up to IL6 and is set out within
HMG IS1.
D.1.3 The impact level depends on the context of the parties likely to be affected.
A significant financial loss to an individual might, for example, be a minor matter
to a large company. This is reflected by the definitions in the Impact Table.
D.2 Impact Table extracts
D.2.1 See overleaf.
Area Sub-category Impact Level 0 - minimal Impact Level 1 - minor A1) Impact on life and safety N/A N/A A2) Impact on provision of
emergency services N/A Disruption to emergency service activities that requires reprioritisation at the local (e.g. police station) level to meet
expected levels of service. A3) Impact on crime fighting N/A N/A A) Public safety and law A4) Impact on judicial proceedings N/A N/A B1)
Impact on public finances Minimal impact (e.g. cost of sundries) Cause a loss to Public Sector of up to £1000 B) Trade, Economics and the
Public Finances B2) Impact on UK trade and commerce N/A N/A C1) Risk to life and safety N/A N/A C2) Impact on the provision of the
service (independent of risks to life and safety) N/A Likely to affect a single citizen C3) Inconvenience and impact on public confidence in
public services May cause minor inconvenience to an individual citizen Likely to reduce an individual citizen's perception of that service
(e.g. a compromise leading to the cancellation of a hospital appointment) C4) Impact on public finances N/A Likely to cause loss to the
Public sector of up to £1000 C5) Impact on non-public finances Likely to have no impact or minimal impact (e.g. cost of sundries) Likely to
cause minor financial loss to any party (e.g. loss of <£100 for an individual or sole trader, loss of <£1000 for a larger business or
organisation) C6) Distress to the public N/A N/A C7) Damage to standing or reputation N/A Likely to cause embarrassment to an individual
citizen or organisation C8) Local y provisioned services with an impact on the personal safety of citizens (e.g. sheltered accommodation)
N/A N/A C9) Locally provisioned services with an impact on the health of citizens N/A Disruption, compromise or flawed working of a local
service which could pose a risk to health C10) Locally provisioned services with no impact on health or safety of citizens Minimal impact
Cancel ation of services to a small number (up to 10) of citizens (e.g. closure of a library or other facility) C) Public Services C11) Local y
provisioned services in support of the Civil Contingencies Act Minimal impact Isolated or minor incident to which a Local Authority is not
able to react within a few days which affects a small number of citizens D1) Communications Minimal impact Local loss of telecoms for a
few hours D2) Power Minimal impact Local outages causing disruption for up to 12hours D3) Finance Minimal impact Minimal impact D4)
Transport Minimal impact Minor disruption of key local transport systems for up to 12 hours D5) Water and Sewage Minimal impact
Breakdown of local water supplies and/or sewage service for more than a day D6) Food and Consumables Minimal impact Local disruption
to the distribution of some essential goods, raw materials, medicines and/or food for up to a week D) Critical National Infrastructure (CNI)
D7) Hazards Minimal impact Minor and short term (up to 1 month) environmental damage/contamination to a local area
e-Government framework for Information Assurance Draft 5.1 Page 141
Impact Level 2 - moderate Impact Level 3 - significant N/A Risk to an individual's personal safety or liberty Disruption to emergency
service activities that requires reprioritisation at the area or divisional level to meet expected levels of service. Disruption to emergency
service activities that requires reprioritisation at the county or organisational level to meet expected levels of service. Hinder the detection of
low-level crime (i.e. crime not defined in legislation as "serious crime") Impede the investigation of, or facilitate the commission of low-level
crime (i.e. crime not defined in legislation as "serious crime"), or hinder the detection of serious crime. Minor failure in local Magistrates
courts Cause a low-level criminal prosecution to col apse; cause a conviction for a low-level criminal offence to be declared unsafe or
referred for appeal. Cause a loss to Public Sector of up to £10,000 Cause a loss to HMG/Public Sector of up to £1 million Undermine the
financial viability of a number of UK SMEs Undermine the financial viability of a minor UK-based or UK-owned organisation N/A Likely to
risk any party's personal safety Likely to affect many citizens Likely to require active management at the county or authority level to meet
expected levels of service. Likely to reduce the perception of that service by many citizens (e.g. compromise leading to an outpatient clinic
closing for a day, with cancel ation of multiple appointments) Likely to result in undermined confidence in the service provider general y (e.g.
public failures at a hospital leading to noticeable lower public confidence in that hospital) Likely to cause a loss to the Public sector of up to
£10,000 Likely to cause a loss to HMG/ Public sector of up to £1 mil ion Likely to cause moderate financial loss to any party (e.g. loss of up
to £1000 for an individual or sole trader, loss of up to £10000 for a larger business or organisation) Likely to cause significant financial loss
to any party (e.g. loss of up to £10,000 for an individual or sole trader, loss of up to £100,000 for a larger business or organisation). Likely to
cause short-term distress to an individual citizen Likely to cause prolonged distress for an individual citizen, or short-term distress for many
citizens Likely to cause loss of reputation for an individual citizen or organisation Likely to cause loss of reputation for many citizens or
organisations Risk to any party's personal safety (e.g. the compromise of the address of a victim of abuse now in sheltered housing, where
it is assessed that there is a low risk of further abuse if such information became known to the original perpetrator) Risk to any party's
personal safety (e.g. the compromise of the address of a victim of abuse now in sheltered housing, where it is assessed that there is a
moderate risk of further abuse if such information became known to the original perpetrator) Disruption, compromise or flawed working of
local services which could pose an increased risk to health (e.g. spread of disease) Authority-wide disruption, compromise or flawed
working of services which could pose an increased risk to health (e.g. spread of disease) Cancellation of services to a number (up to 100)
of citizens (e.g. closure of a library or other facility) Cancel ation of multiple services to a number (up to 1000) of citizens leading to financial
losses (up to £10,000) Isolated or minor incident to which a Local Authority is not able to react within a few days which affects a number of
citizens/local businesses Significant incident to which a Local Authority is not able to react within 24hours which affects a large number of
citizens/local businesses - e.g. significant flooding, fire, contamination or explosion. Local loss of telecoms for up to 12 hours Local loss of
telecoms for up to 24 hours Local outage causing distribution for up to 24 hours Loss of power in a region causing distribution for up to 24
hours Embarrassment to a Financial Company leading to minor loss of confidence Major loss of a Leading Financial company of £mil ions
Minor disruption of key local transport systems for up to 24 hours Major disruption of key local transport systems for up to 24 hours
Breakdown of local water supplies and/or sewage service for more than a week Breakdown of local water supplies and/or sewage service
or prolonged drought (up to 1 months) Local disruption to the distribution of some essential goods, raw materials, medicines and/or
disruption of food for up to a month Regional disruption to the distribution of some essential goods, raw materials and medicines and/or
widespread disruption of food for up to a week Minor and short term (up to 6 months) environmental damage/contamination to a local area
Major and short term (up to 12 months) environmental damage/contamination to a local area
E Identity registration examples
E.1 General
E.1.1 This annex presents some examples of acceptable remote and online
evidence for the identity registration of an individual. Details of the specific
documents that may be accepted as suitable items of evidence, and a further
discussion of acceptable countermeasures for the registration of individuals and
organisations, may be found within the HMG minimum requirements documents
for the verification of the identity of individuals181 and organisations.182
E.2 Registration IL1 examples Registration IL1 remote identity registration
examples
E.2.1 For remote identity registration of an individual at Registration IL1, a
personal statement as per face-to-face identity registration must be provided. A
sufficient level of assurance that the identity asserted corresponds to a real-world
identity, and that the application was made by the client whose identity is
asserted, might be obtained via any one of the fol owing procedures:
<li>independent verification of the client's address (eg using a credit reference
agency or national identity register) and direct mailing of identity registration
information to the client at that address, fol owed by written acknowledgement
(eg a signed receipt) by the client that they have received this information;
- telephone contact with the client prior to completing the identity registration
on an independently verified home or business number, utilising a minimum of
two pieces of personal identity security information that have previously been
provided during the setup process;
- internet sign-on fol owing verification procedures where the customer uses
security codes, tokens and/or other passwords which have been set up during
the identity registration process and provided by out-of-band means (eg mail or
secure delivery) to the named individual at an independently verified address;
- an initial payment by cheque drawn on a personal account in the client's
name at a UK or EU bank or building society.
181 HMG's minimum requirements for the verification of the identity of individuals, Version 2.0, January
2003. This document may be downloaded from the Cabinet Office web-site,
http://www.cabinetoffice.gov.uk/. 182 HMG's minimum requirements for the verification of the identity of
organisations, Version 2.0, January 2003. This document may be downloaded from the Cabinet Office web-
site, http://www.cabinetoffice.gov.uk/.
Registration IL1 online identity registration examples
E.2.2 For online identity registration of an individual at Registration IL1, a
personal statement as per face-to-face identity registration must be provided. A
sufficient level of assurance that the identity asserted corresponds to a real-world
identity, and that the application was made by the client whose identity is
asserted, might be obtained via any one of the fol owing procedures:
- use of the Verified by VisaTM (VbV) or MasterCard SecureCodeTM services;
where an individual presents a valid and current card and associated pre-
registered password, this is considered to be sufficient to demonstrate that the
card was sent to a valid address by a bank, and that the client's identity was
validated by the issuing bank at the time that the VbV or SecureCode password
was set up; this is taken as providing reliable third-party corroboration;
- use of the identity verification services of a Credit Industry Fraud Avoidance
System (CIFAS) Participating Agency183 to provide evidence of real-world identity
and of activity in the community, where the parameters of the identity checking
process have been previously agreed with the Agency as meeting the evidence
requirements at this level (ie any combination of two from: one piece of evidence
of identity; one piece of evidence of activity in the community; one piece of third-
party corroboration);
- an initial payment by debit card or credit card drawn on a personal account in
the client's name at a UK or EU bank or building society; this method of
confirmation may be extended to e-Government services where no payment is
required by withdrawal of a nominal sum which is immediately refunded.
E.3 Registration IL2 examples
Registration IL2 remote identity registration examples
E.3.1 For remote identity registration of an individual at Registration IL2, a
personal statement as per face-to-face identity registration must be provided. A
sufficient level of assurance that the identity asserted corresponds to a real-world
identity, and that the application was made by the client whose identity is
asserted can be obtained via any one of the fol owing procedures:
- provision of at least two pieces of evidence to demonstrate evidence of
identity (eg passport and birth certificate), plus two separate documents
demonstrating activity in the community (eg a recent bank statement and council
tax invoice); one or two pieces of documentary evidence may be replaced by
third-party corroboration;
- provision of at least two pieces of third-party corroboration from separate
independent sources; these must be organisations registered with, regulated and
inspected by a statutory British public body and which can
183 Such as Equifax, Experian or Cal credit.
corroborate details about the client that are unlikely to be known to other
persons; exceptional y, corroboration from only one third-party may be sought, in
cases where the registration authority is able to check elements of the client's
statement against its own or published records, and that third-party has access to
a number of sources of information which wil be known only to the client and
those sources; also, the third-party must be able to corroborate a number of
pieces of information concerning the client that is unlikely to be available to
potential imposters.
Registration IL2 online identity registration example
E.3.2 For online identity registration of an individual at Registration IL2, a
personal statement as per face-to-face identity registration must be provided. A
sufficient level of assurance that the identity asserted corresponds to a real-world
identity, and that the application was made by the client whose identity is
asserted, would require both of the fol owing to be provided:
- submission of passport information and use of the Identity and Passport
Service (IPS) passport checking service to confirm the identity of the passport
holder and that the passport is valid and has not been reported stolen;
- use of the identity verification services of a CIFAS Participating Agency to
provide evidence of real-world identity and of activity in the community, where the
parameters of the identity checking process have been previously agreed with
the Agency as meeting the evidence requirements at this level (ie one piece of
evidence of identity, two pieces of evidence of activity in the community and two
pieces of third-party corroboration).
E.4 Registration IL3 examples
Registration IL3 remote identity registration examples
E.4.1 Remote identity registration must only be undertaken at Registration IL3 if
more than one piece of documentary evidence of both identity and activity in the
community can be provided, plus third-party corroboration from more than one
source. Further information should always be sought in the case of any doubt or
inconsistency. E.4.2 Remote identity registration without submission of
documentary evidence may only be used if strong corroboration of identity can
be obtained from several (at least four) different trustworthy sources already
known to the RA, and which can corroborate evidence that realistical y can only
be known to the client and the corroborator. In these situations, advice should be
sought from the Information Commissioner.
Registration IL3 online identity registration example
E.4.3 To date, no suitably assured processes have been identified to enable a
client to register their identity online without remote interaction at Registration
IL3.
However, it is expected that cross-checking against the proposed IPS identity
register wil enable e-Government service providers to obtain sufficient
assurance of a client's real-world identity to Registration IL3 and above. In the
interim, where an overwhelming business benefit can be demonstrated, the
procedures set out for Registration IL2 may be used in conjunction with thorough
(Confidentiality/Integrity IL3) Accounting and Audit measures. This interim
measure is strongly deprecated, owing to the significant degradation of the
security provided, and is only acceptable while no alternative procedure is
available. If this interim measure is used, a timescale for migration to a more
acceptable method must be explicitly specified in the RMADS.
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