Industry:Draft NIST SP 800-122

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Submission Response
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Draft Text version 2
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3.2.5 Access to an Location of the PII
Explanation Many organisations are now using web technologies to deliver functional applications. Teleworkers may access web-enabled systems directly and this means that PII is stored in, and transferred from, many more locations including systems hosted by third parties, network devices and user's own computers.

Suggested change Amend the sentence which ends "Another element is the scope of access to the PII, such as whether the PII needs to be accessed from teleworkers' systems and other systems outside the direct control of the organization." to "Another element is the scope of access to the PII, such as whether the PII needs to be STORED ON OR accessed from teleworkers' systems and other systems SUCH AS WEB APPLICATIONS outside the direct control of the organization."

3.3.3 Example 3: Fraud, Waste, and Abuse Reporting Application
Explanation The example states that the data is collected using a web-enabled system. Therefore the database is not just "accessed by a few people who investigate fraud, waste..." - the web site is publicly available, and submissions are written to the (web) database online. There is a potential here for such information to be divulged to unauthorized users while stored in the online database or in transmission through the existence of security weaknesses that can be exploited. Even internally, the intention might be that only a few people access the database, but that may not be the case.

Suggested change In the section "Access to and location of the PII: The database is only accessed by a few people who investigate fraud, waste, and abuse claims. All access to the database occurs only from the organization's own systems.", change this to be "Access to and location of the PII: THE DATA EXISTS ON A SERVER OUTSIDE THE ORGANIZATION'S NETWORK (THE ONLINE SYSTEM) AND ANY VULNERABILITIES IN THE ONLINE WEB APPLICATION COULD LEAD TO A BREACH OF THE PII.  ONCE TRANSFERRED INTERNALLY, the database is only MEANT TO BE accessed by a few people who investigate fraud, waste, and abuse claims - only from the organization's own systems.".

4.3 Security Controls
Explanation An area where "greater protections" is typically required is in web-enabled applications. OWASP is leading the way in the development of open guides, tools and standards for web application security verification.

Suggested change At the end of the first paragraph (before the bulleted items) add, "SEE THE OPEN WEB APPLICATION SECURITY PROJECT APPLICATION SECURITY VERIFICATION STANDARD (ASVS) FOR ONLINE WEB SYSTEM SECURITY CONTROL VERIFICATION.". (footnote link http://www.owasp.org/index.php/Category:OWASP_Application_Security_Verification_Standard_Project)

Appendix A, Scenario 2: Protecting Survey Data
Explanation This scenario concerns an email with a hyperlink to an online survey. The user's data must not compromised while they are entering the data into the application. It is also important that the PII data collected needs to be protected while it is stored on the web-enabled systems.

Suggested change In the "additional questions for the scenario", add a new item between items 2 and 3 "HOW ARE THE DATA ELEMENTS COLLECTED, STORED AND USED SECURELY IN THE ONLINE SYSTEMS".

Initial Comments
Possibly four areas where OWASP might comment - initial ideas below (no justifications provided yet).

In "3.2.5 Access to an Location of the PII", amend the sentence which ends "Another element is the scope of access to the PII, such as whether the PII needs to be accessed from teleworkers' systems and other systems outside the direct control of the organization." to "Another element is the scope of access to the PII, such as whether the PII needs to be STORED ON OR accessed from teleworkers' systems and other systems SUCH AS WEB APPLICATIONS outside the direct control of the organization.".

In "3.3.3 Example 3: Fraud, Waste, and Abuse Reporting Application", in the section "Access to and location of the PII: The database is only accessed by a few people who investigate fraud, waste, and abuse claims. All access to the database occurs only from the organization's own systems.", change this to be "Access to and location of the PII: THE DATA EXISTS TEMPORARILY ON A SERVER OUTSIDE THE ORGANIZATION'S NETWORK (THE ONLINE SYSTEM) AND ANY VULNERABILITIES IN THE ONLINE WEB APPLICATION COULD LEAD TO A BREACH OF THE PII.  ONCE TRANSFERRED INTERNALLY, the database is only accessed by a few people who investigate fraud, waste, and abuse claims MEANING access to the INTERNAL database occurs only from the organization's own systems.".

In "4.3 Security Controls", add at the end of the first paragraph (before the bulleted items), "SEE THE OPEN WEB APPLICATION SECURITY PROJECT APPLICATION SECURITY VERIFICATION STANDARD (ASVS) FOR ONLINE WEB SYSTEM SECURITY CONTROL VERIFICATION.". (footnote link http://www.owasp.org/index.php/Category:OWASP_Application_Security_Verification_Standard_Project)

In "Appendix A, Scenario 2: Protecting Survey Data" under the "additional questions for the scenario", add a new item between items 2 and 3 "HOW ARE THE DATA ELEMENTS COLLECTED, STORED AND USED SECURELY IN THE ONLINE SYSTEMS".

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