OCIO/G4.8a Government guideline on cyber security ISMF Guideline 8a An approach to classification using the ISMF BACKGROUND Version 3 and later of the South Australian Information Security Management Framework [ISMF] introduced a new classification structure for confidentiality (refer ISMF Guideline 8b) and reinforced the importance of classifying information and associated information assets (such as ICT platforms and services) based on Integrity, Availability and Confidentiality requirements. Protection efforts should be prioritised for those assets that are considered critical, and to information that is of high value to supporting the business’ ongoing operations and resilience. This guideline supports implementation of ISMF Policy Statement 8. PRE-REQUISITE DOCUMENTS The following documents should be read in conjunction with this guideline: ISMF Guideline 8b describes the new classification scheme for confidentiality and provides translation from the earlier scheme used within government to the new markings. Annex B of the ISMF contains a flow-chart describing the confidentiality marking structure. Table 1 of the ISMF describes the Dissemination Limiting Markers [DLMs] used by SA Government agencies. These alert recipients and custodians of information as to special handling requirements surrounding confidentiality and intended audience for materials that use the information. Release requirements are often governed by legislation. Table 2 of the ISMF describes the protective markings used by SA Government agencies. These are classifications indicating that the information requires a heightened level of protection to ensure confidentiality. Examples include personnel vetting and security clearances to access the information, and stringent storage and access methods for ICT systems and hardcopy documentation containing information at this level. Table 3 of the ISMF describes the availability and integrity classifications used by SA Government agencies. ISMS Statement of Applicability tool is a spread-sheet based tool to facilitate the recording of agency decisions on what policies, standards and controls are in place against a particular system, workplace function or geographic location. GUIDANCE This guideline outlines a process for classifying information and associated information assets. Essentially the classifications are a result of characterising attributes of information to determine a set of requirements (or assign a value to the information) for an organisation and/or its stakeholders (including customers and the public). The outcome is that corresponding protective ISMF Guideline 8a ISMF Guideline 4 markings are associated with the information (or information asset) so that the information risk management techniques described in the ISMF can be applied to ICT systems and organisational processes in order to proportionately protect and maintain confidence in an agency’s ability to deliver information based services. RESPONSIBLE INFORMATION SHARING A key attribute of information classification, is to recognise that all information is shared at some point in its lifecycle. No matter how sensitive or restricted the destination audience may be, information is generated (or created), stored and then used by an individual or a group by applying the ‘need-to-know’ principle. This principle means a person must have a legitimate need to access the classified information assets to carry out their official duties. Other justifications, such as position of authority, or the desire to enter controlled areas or access information for the sake of convenience, are not valid. Once information classifications have been determined, the business-driven risk-based approach to cyber security of the ISMF requires decisions to be recorded on how identified risks have been addressed in order to provide an adequate level of assurance to the business that cyber security controls and protection mechanisms are in place, being used and effective. Some examples of the varying degrees of responsible information sharing are illustrated below: Emergency management and crisis response information is generally distributed on a broad public scale, but requiring exceptionally high degrees of accuracy (integrity) and availability in order to inform the community and emergency services personnel in a timely and accurate manner. Payroll processing and financial information need a high degree of accuracy and will have varying requirements in terms of its availability requirements. This is often driven by calendar based events, such as salary processing periods, during budget bids or during forecasting events for significant initiatives such as major projects. Information Sharing Guidelines for Promoting the Safety and Wellbeing of Children, Young People and their Families - these guidelines deal with the legal and practical framework that supports appropriate information sharing for the provision of integrated support to children, young people and their families. Medical and healthcare information, particularly patient data needs to be extremely accurate and held in the strictest confidence to protect patient privacy and wellbeing yet is still shared between medical practitioners that have a legitimate ‘need-to-know’. Criminal investigations, operations and counter-terrorism undertakings require significantly elevated degrees of confidentiality to be applied. The sheer diversity and complexity of information types used within and between governments means that no single process for determining the value of information will work in all scenarios. By implementing an approach that accounts for the three dimensions of information security (confidentiality, integrity and availability), the likelihood of success in meeting business operating objectives is significantly improved. Government guideline on cyber security An approach to classification using the ISMF (v1.0) Page 2 of 7 ISMF Guideline 8a ISMF Guideline 4 BENEFITS REALISATION By balancing the ‘need-to-protect’ information with the ‘need-to-publicly disclose’ and share information, visible benefits are realised. As open-government initiatives in multiple jurisdictions gain traction, information management practises must transition to account for the ever increasing use of social media and other bi-directional information systems as a channel for community consultation. The benefits of responsible information sharing include: User experience both within and external to government o Information is easy to find and can be relied upon o Services are interactive and timely Elimination of delays o Information on demand (i.e. readily shared and accessible when required) o Accessible by leveraging the internet, including mobile devices and emerging technologies Reduction in costs and increase in organisational efficiencies o Lowers cost of service delivery o Fosters greater use of ‘self-service’ capabilities o Interactive government is an agile and consultative government Accurate and timely information o Timely information is achieved because availability requirements have been considered o Accurate information is more likely because integrity requirements have been considered Maintaining trust and confidence in government as a supplier and custodian of information o Reliable and secure information services engender trust and confidence. This is reflected by organisational capability, capacity and communication. Government guideline on cyber security An approach to classification using the ISMF (v1.0) Page 3 of 7 ISMF Guideline 8a ISMF Guideline 4 CHARACTERISING THE VALUE OF INFORMATION The following process diagram presents an overview of the necessary process flow required to establish a value for the information or asset using a classification process. This facilitates managing and recording any risks identified by the business using the ISMF as a control mechanism. This process shifts thinking from a conventional confidentiality based approach to consider the three dimensions of information management and security in order to meet business level requirements and objectives. The process recognises that public information may require exceptionally high degrees of integrity (accuracy) and availability (and by association that availability requirements may change based on calendar or event driven periods, a notion of ‘peakdemand’ for certain types of information). Confidentiality of information is also embedded in the process, however this approach recognises that in many instances, confidentiality protections are applied to prevent corruption, theft or denial of service to important information upon which the business or the broader community rely, including information held about persons: •Work with Business Owners to understand what inaccuracies to the information can be tolerated prior to undertaking corrections or reissuing the information to be classified. The ultimate determination of information value must come from the business itself. How accurate must the information be •Determine the extent of consequences if the information contains errors, becomes corrupted or de-faced or contains omissions. (Table 3 of the ISMF for Integrity) • Information is bound to become unavailable at certain points in time. Whether the information is unavailable due to system outages or planned maintenance windows or as a result of unintended and unplanned events. The determination of a 'tolerable outage' must be accepted by the business. What is the tolerable outage for the information • Tolerable outages can drive an Availability classification for the information. Factors to consider include the dependence the business, its customers or the community has on the information and the business impacts a disruption or loss of access to the information may cause. Availability requirements may change at certain times whether event or calendar driven. (Table 3 of the ISMF for Availability) •Establishing the intended audience for information is generally sufficient to determine a confidentiality classification. Who is the intended audience •Factors to consider include how information is shared and who needs to know this information. The vast majority of information in government is public or 'For Official Use Only' meaning that is to be retained but may be shared within government. (Table 1 and 2 of the ISMF for Confidentiality) •Information that is not destined for public or whole of government consumption is generally driven by commercial, legislative or regulatory requirements. Sensitive information is marked according to the enactment or consideration that warrants additional controls around handling and storage. Legislative and regulatory requirements •Information that requires secrecy provisions and security clearances due to its content and potential for endangering individuals, the government, its partners or other jurisdictions requires a protective marking. Such information requires heightened security controls and is more costly to maintain. This information also requires special arrangements for disposal and destruction . Government guideline on cyber security An approach to classification using the ISMF (v1.0) Page 4 of 7 ISMF Guideline 8a ISMF Guideline 4 CONVEYING PROTECTIVE MARKINGS IN DOCUMENTS Agencies should formulate localised procedures and processes for applying protective markings to information on systems and within documents or other datasets. It is often impractical and confusing to apply markings to headers and footers of documents and letters that are destined for public consumption. The following general guidance may assist agencies in applying markings to these types of material: 1. Public documents including policy statements, initiatives, disclosures and corporate materials The use of a ‘DLM block’ or similar document control mechanism within the document may assist in fulfilling obligations with respect to records management, security and release and revision information. The advantage of such an approach is that members of the public are easily able to identify the currency and validity of the information they have obtained. It is recommended that the classification/DLM descriptor details the three axis of security classification for Confidentiality, Integrity and Availability as this greatly facilitates ICT support personnel in fulfilling their obligations to meet required service levels as contractually determined by the business for the information they are entrusting to their providers. By example, a DLM with records management and security classification information is applied to the last page of this guideline. 2. Email, letters, memorandums and other correspondence directed to members of the public or commercial entities A common-sense approach to indicating security treatments and records management needs to be applied in correspondence to individuals and commercial entities. Examples include a simple marking such as ‘Sensitive: Personal’ or ‘Sensitive: Medical’ appearing somewhere on the letter, receipt or other communique may be entirely appropriate if the level of detail contained in the correspondence warrants this marking and treatment. In other instances, no marking may be warranted at all. When dealing with commercial entities, it is important to recognise that the marking of ‘Sensitive: Commercial’ does not apply in a blanket fashion. Due consideration should be applied to the content of the information being communicated. Sensitive commercial information would be information that would give an unfair advantage to competitors or jeopardise the commercial entity in some such way should the information be released or leaked inadvertently. A simple quotation for list price items with no substantial discounts, or items that are already published by the vendor in a non-competitive manner (such as at an online shopping site or as a pricelist) would not give rise to use of this marking. 3. Documents not authorised for public release but retained and used within and between governments, or within a single agency Although ‘For Official Use Only’ is the most commonly applied marking for collaboration and sharing within and between governments, information may be exchanged on a ‘need-to-know’ basis at many classification levels. The most important factor to apply to information that is essentially for internal use, is that the marking should appear somewhere in the header or footer of each page. The Australian Government has mandated an approach that requires the marking to be applied in both the header and footer of each page. This requirement does not extend to the Government of South Australia although it has been applied in many agencies. The primary requirement is that each page clearly conveys the handling and treatment requirements for the information contained on that page (or section). Government guideline on cyber security An approach to classification using the ISMF (v1.0) Page 5 of 7 ISMF Guideline 8a ISMF Guideline 4 The Australian Government guideline on marking of documents provides excellent guidance on this matter and may be used as a template for development of agency specific procedures and guidance, bearing in mind the nuances of the South Australian classification scheme which factors in additional treatments and markings for materials that are: commercial, medical, SA Cabinet related etc. For further information on marking guidelines, consult the document entitled ‘Protectively marking and handling sensitive and security classified information’ which is available for download from http://www.protectivesecurity.gov.au/ AGGREGATED INFORMATION MAY TRIGGER SPECIAL HANDLING OBLIGATIONS The sum total of multiple information sets stored in a single device, service or physical location may lead to greater protection efforts being required when these sets are considered in their entirety (i.e. the compilation of multiple data sets). The principal of aggregated information protection and management is particularly relevant to databases, inventories and multiple instances of Official Information that has not been authorised for public release. In instances where there are multiple lesser classified datasets stored by and processed on a common ICT system or platform, a comprehensive risk assessment may warrant the system or platform being classified at a higher level than that of the individual datasets it holds. Such a notion is particularly relevant for example if there is a substantial quantity of Sensitive information on a server platform or disk storage array etc. Although this guideline focuses on the aggregation of electronic information; the ideas, principles and themes are also applicable to the management of aggregations of hard copy information. For further information on the management of aggregated information, consult the document entitled ‘Management of aggregated information’ which is available for download from http://www.protectivesecurity.gov.au/ ADDITIONAL CONSIDERATIONS Agencies should contact their Information Technology Security Adviser [ITSA] for further advice and guidance on agency specific classification procedures and guidelines. Information received by another entity, whether it is commercial or from government in other jurisdictions must not have its protective markings altered or changed without the express written consent of the originator of the information. There is no protective marking that prohibits, inhibits or prevents an agency from sharing, using and collaborating information provided that there is a legitimate and established ‘needto-know’. The primary purpose of information classification is to ensure that protection and management efforts are proportionate to the value and sensitivity of the information being processed. Information that needs to be restricted to a given audience, such as a single agency, a committee or other governance group or a particular workforce function should consider the use of the ‘Eyes Only’ caveat in their protective markings. Applicable caveats for use in South Australian government agencies are described in detail in table 4 of the ISMF. Government guideline on cyber security An approach to classification using the ISMF (v1.0) Page 6 of 7 ISMF Guideline 8a This guideline does not constitute an absolute or mandatory method for classifying information. It is merely a good practice guideline applied to the protective security policy position and operating characteristics of the Government of South Australia at the time of writing. The individual requirements and operational characteristics of agencies will have direct bearing on what measures are implemented to mitigate identified risk(s) and how such outcomes are achieved. REFERENCES, LINKS & ADDITIONAL INFORMATION OCIO/F4.1 Government of South Australia Information Security Management Framework [ISMF] PC030 Government of South Australia Protective Security Management Framework [PSMF] AS/NZS ISO/IEC 27002:2006 Australian Government Protective Security Policy Framework [PSPF] ID OCIO_G4.8a Classification/DLM PUBLIC-I2-A1 Issued December 2012 (re-issued as ISMF Guideline 8a from Guideline 15 – February 2014) Authority Security and Risk Steering Committee Master document location Q:\SecurityRiskAssurance\Policy Development Sub-program\Policy and Standards\ISMF\ISMFguidelines\ISMFguideline8a(information classification).docx Records management File Folder: 2011/15123/01 - Document number: 7078872 Managed & maintained by Office of the Chief Information Officer Author Jason Caley, Principal Policy Adviser Reviewer Peter Fowler MACS (Snr. CP), IP3P, CISM, CGEIT, CRISC, MAIES , Director Security and Risk Assurance Compliance Discretionary Review date February 2016 To attribute this material, cite the Office of the Chief Information Officer, Government of South Australia, ISMF Guideline 8a. This work is licensed under a Creative Commons Attribution 3.0 Australia Licence Copyright © South Australian Government, 2012. Disclaimer