Reference #: ITD-SEC-16.1
Issue Date: March 6, 2014
Issue #: 1
Table of Contents
This policy articulates requirements that assist management in defining a framework that ensures compliance with the overall information security goals of the Commonwealth including without limitation compliance with security-related laws, regulations, policies, standards and contractual provisions to which their IT resources and data are subject.
Agencies must ensure the appropriate security controls that meet or exceed the compliance requirements associated with their information assets, and provide the confidentiality, integrity and availability of the data for which the agency is responsible, are in place.
Agency Heads must have controls in place that provide reasonable assurance that security objectives are addressed. Agencies are responsible for their organization’s ongoing compliance with security-related statutory, regulatory and contractual requirements.
All agencies and entities governed by the overarching Enterprise Information Security Policy must adhere to requirements of this supporting policy.
- Executive Department Agencies,  in addition to any agency or third party that connects to the Commonwealth’s wide area network (MAGNet), must comply with this policy.
- Executive Department Agencies are required to ensure compliance by any business partner that accesses Executive Department IT Resources or shared environments, e.g. MAGNet; and
- Executive Department Agencies are required to ensure compliance by third parties in any aspect of the process of providing goods and services to their agency. These include, but are not limited to, electronic data collection, storage, processing, disposal, dissemination and maintenance. Third parties that interact in any way with Executive Department Commonwealth IT Resources, e.g. MAGNet, are required to comply with this policy.
Other Commonwealth entities are encouraged to adopt, at a minimum, security requirements in accordance with this Enterprise IT Security Compliance Policy or a more stringent agency policy that addresses agency specific and business related directives, laws, and regulations.
Agencies are required to adopt and implement agency specific standards and procedures where they are required by policies and standards promulgated by the Commonwealth CIO; to follow security-related federal and state legal mandates (Publication 1075, PCI, Executive Orders, etc.); and meet security-related contractual requirements, in order to ensure the confidentiality, integrity, and availability of information assets. Agencies must implement the requirements of this policy and ensure that they are addressed in contracts entered by them with third parties where such contracts pertain to the agency’s information assets and IT Resources.
1 Data Protection: Agencies must develop and implement uniform policies and standards that meet the compliance requirements associated with the sensitivity classification of their data as articulated in the Enterprise Information Security Standards: Data Classification, and in any other applicable laws, regulations, policies, standards, and contracts, by:
1.1. Developing documented Information Security Programs, as required by the Enterprise Information Security Policy, to govern the collection, handling, storage, processing, dissemination, and disposal of information based on its sensitivity classification.
1.2. Collecting the minimum quantity of personal information reasonably needed to accomplish the legitimate purpose for which it is collected.
1.3. Securely protecting high sensitivity data including but not limited to personal information, against unauthorized access, use, destruction, modification, disclosure, or loss.
1.4. Using information security controls as stipulated by NIST and ISO 27002 standards.
1.5. Using storage methods that include appropriate security controls based on classification of data.
1.6. Encrypting high sensitivity data or protecting it with equivalent compensating controls while at rest.
1.7. Providing access to High Sensitivity Data to only those persons and entities which have been authorized to have such access as part of their job functions.
1.8. Destroying Highly Sensitivity Data as soon as it is no longer needed or required per applicable data retention requirements and/or statute(s) or agency business needs.
1.9. Comply with Executive Order 504 and address within the agency’s Information Security Program (ISP) the administrative, technical, and physical controls required to safeguard personal information regardless of how it is collected, stored, processed, disseminated, or destroyed.
1.10. Providing and enforcing mandatory, biennial information security training for all agency members including Agency Head, Managers, Supervisors, employees, and contract employees, and training new employees and contractors. at the time they commence work as part of standard employee orientation practices.
2 Patent, Copyright and Trade Secret Protection: Agencies must implement appropriate procedures to ensure compliance with the statutory, regulatory and contractual requirements imposed on the use of third party intellectual property, including without limitation proprietary software and information , including:
2.1. Communication to all agency employees and contractors of the proper use of third party intellectual property.
2.2. Acquisition of software licenses and proprietary information from reputable sources to ensure that intellectual property rights are not violated by the agency’s use thereof.
2.3. Engagement in sound software asset and proprietary information management practices, including:
- Maintenance of records demonstrating software and information ownership and licensing including proof of ownership (i.e. procurement records, copies of licenses, master CDs, manuals, product keys).
- Limitation of access to and use of software and proprietary information in a manner consistent with the license under which the agency has acquired it
3 Plan of Action and Milestones (POAM): Agencies must implement a plan of action and milestones (POAM) to track, evaluate and deliver compliance against the requirements of EO504, state law, Federal law, contracts and policies. The following must be addressed by the agency’s POAM:
3.1. Annual self-audit that measures compliance against EO504.
3.2. Security reviews, self-audits or independent audits required to comply with state or Federal law, contracts (e.g. PCI reviews) or policies.
3.3. Collaboration with ITD’s Assurance Compliance Office.
3.4. Compliance with all applicable Office of the Comptroller (OSC) requirements including but not limited to:
- Use of an OSC approved contractor for any vendor hired to conduct an official third party review, including audits.
- Reporting findings that result from any official third party review to the ANF Compliance Officer.
3.5. Use a formal risk assessment and treatment methodology as articulated in the Enterprise IT Asset and Risk Management Policy to aid in selecting departments, systems, applications, etc. for inclusion taking into consideration:
- Impact of processes on other organization activities
- System development or process change
- Statutory, regulatory and contractual compliance issues
- Known or perceived control concerns
- Audit history
- Implementation of controls contained within the scope of the ISP and/or ESP.
3.6. Implement a mechanism to track remediation efforts in the POAM to ensure that future security reviews, audits and self-audits do not reveal previous findings (other than such findings which risks have been deemed acceptable).
3.7. Implement a process for the review and maintenance of the POAM, taking into account new agency activities and programs in conjunction with organizational and overall environmental (e.g., administrative, technical, and physical) changes within the agency.
3.8. Define a security self-audit schedule detailing agency assets, processes, related scope and criteria, the planned frequency of occurrence and audit methods.
3.9. Provide audit coverage of all high-risk activities and/or departments as identified within the scope of the audit, and assign resources to perform such audits according to the agency’s defined audit schedule.
3.10. Document audit activities and results per audit requirements as appropriate and store the audit documentation in a secure location.
4 Compliance with security policies and standards: Agencies are responsible for ensuring that all relevant statutory, regulatory, and contractual requirements to which they are subject and the agency’s approach to meeting those requirements are explicitly defined, documented, and kept up to date for their information systems, organization and environment.
- All contracts entered into from the effective date of this policy must contain provisions requiring contractors to certify that they have read and will comply with the ISP, ESP, guidelines, standards, and policies that apply to the work they will be performing, and specifically to EO 504 standards. The current version of the OSD Standard Contract Form includes such language.
- Contracts must require that subcontracts entered by contractors include language which (a) requires subcontractors to comply with hese provisions and (b) requires contractors to enforce these provisions against their subcontractors. In addition, requests for quotations and requests for responses and other contract documents must include any other reasonable security procedures and practices necessary to protect personal information, in particular the standard EO 504 solicitation and contract language required by ITD and posted on its EO504 website.
All agencies and entities governed by the overarching Enterprise Information Security Policy are subject to the referenced roles and responsibilities in addition to those specifically stated within this supporting policy. The roles and responsibilities associated with implementation and compliance with this policy follow:
Assistant Secretary for Information Technology
- Develop mandatory standards and procedures for agencies to follow before entering into contracts that will provide third parties with access to electronic High Sensitivity Data including but not limited to personal information or IT systems containing such information.
- The Assistant Secretary for Information Technology is responsible for the approval and adoption of the Enterprise Information Technology Compliance Policy and its revisions.
Secretariat Chief Information Officer (SCIO) and Agency Head
- SCIOs and Agency heads are responsible for exercising due diligence in adhering to the requirements contained in this policy.
- Provide communication, training and enforcement of this policy that support the security goals of the Secretariat, its agencies and the Commonwealth.
- The Agency Heads are responsible for ensuring compliance with all applicable laws, regulations, and contractual obligations related to the security of High Sensitivity Data.
Secretariat or Agency Information Security Officer (ISO)
- Ensure that the goals and requirements of the Enterprise IT Security Compliance Policy are implemented and met.
Enterprise Security Board (ESB)
- Recommend revisions and updates to this policy and related standards.
Information Technology Division (ITD)
- After review of any related recommendations of the Enterprise Security Board, issue revisions and updates to this policy and related standards.
- Required to comply with agency implementation of this policy at a minimum or a more stringent agency specific policy including:
- Attestation and certification that third parties have read Executive Order 504 and this policy.
- Review and compliance with all information security programs, plans, guidelines, standards and policies that apply to the work they will be performing for their contracting agency.
- Include in their subcontracts terms that require subcontractors to comply with these provisions
- Enforce this policy against their subcontractors
Primary references that were used in development of this policy include:
Executive Order 504
Additional information referenced includes:
M.G.L., Ch 93H
M.G.L., Ch 93I
M.G.L., Ch 66A
HIPAA Security Rule
Key terms used in this policy have been provided below for your convenience. For a full list of terms please refer to the Information Technology Division’s web site where a full glossary of Commonwealth Specific Terms is maintained.
No terms specific to this policy have been included.
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Published Enterprise IT Security Compliance Policy
Accessibility remediation, corrected section 2 numbering – no content changes
 The Executive Department is comprised of the Executive Branch minus the Constitutional Offices, i.e., the State Auditor, State Treasurer, the Attorney General, and the Secretary of the Commonwealth. While the Governor’s Office is also a Constitutional Office, it is covered by all ITD standards and policies.