Difference between revisions of "User:Shawndouglas/sandbox/sublevel3"

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====CA-1 Security assessment and authorization policy and procedures====
This control recommends the organization develop, document, disseminate, review, and update security assessment and authorization policies and procedures. It asks organizations to not only address the purpose, scope, roles, responsibilities, and enforcement of security assessment and authorization action but also to address how those policies and procedures will be implemented, reviewed, and updated.


'''Additional resources''':
==The laws themselves==
* [https://csrc.nist.gov/publications/detail/sp/800-12/rev-1/final NIST Special Publications 800-12, Rev. 1], pages 60–61
* [https://csrc.nist.gov/publications/detail/sp/800-37/rev-1/final NIST Special Publications 800-37, Rev. 1]
* [https://csrc.nist.gov/publications/detail/sp/800-53a/rev-4/final NIST Special Publications 800-53A, Rev. 4]
* [https://csrc.nist.gov/publications/detail/sp/800-100/final NIST Special Publications 800-100], pages 96–112
* [https://www.limswiki.org/index.php/LII:LIMSpec/Maintaining_Laboratory_Workflow_and_Operations#7._Document_management LIMSpec 7.1, 7.2]


====CA-2 Security assessments====
===1. Federal Telecommunications Act of 1996, Section 255 ([https://www.law.cornell.edu/uscode/text/47/255 47 U.S.C. § 255 - Access by persons with disabilities])===
This control recommends the organization develop, document, disseminate, review, and update a security assessment plan. This plan is focused on helping the organization ensure the assessment procedures, environment, team, roles, and responsibilities are defined and the security controls are correctly implemented, operating as intended, and meeting the established security requirements. The assessments should happen at defined frequency. Additionally, the organization is encouraged to report on the results of the implemented plan and corresponding assessments, disseminating the results to authorized personnel or roles.


'''Additional resources''':
<blockquote>'''(b) Manufacturing'''
* [https://csrc.nist.gov/publications/detail/sp/800-37/rev-1/final NIST Special Publications 800-37, Rev. 1]
A manufacturer of telecommunications equipment or customer premises equipment shall ensure that the equipment is designed, developed, and fabricated to be accessible to and usable by individuals with disabilities, if readily achievable.
* [https://csrc.nist.gov/publications/detail/sp/800-39/final NIST Special Publications 800-39]
* [https://csrc.nist.gov/publications/detail/sp/800-53a/rev-4/final NIST Special Publications 800-53A, Rev. 4]
* [https://csrc.nist.gov/publications/detail/sp/800-115/final NIST Special Publications 800-115]
* [https://csrc.nist.gov/publications/detail/sp/800-137/final NIST Special Publications 800-137]
* No LIMSpec comp (organizational policy rather than system specification)


====CA-2 (1) Security assessments: Independent assessors====
'''(c) Telecommunications services'''
This control enhancement recommends the organization employ some type of independent assessment team with a predetermined level of required independence to conduct security control assessments. that Ensuring the team is free from perceived or actual conflict of interest is important, and NIST adds that "[o]rganizations recognize that assessments performed for purposes other than direct support to authorization decisions are, when performed by assessors with sufficient independence, more likely to be useable for such decisions, thereby reducing the need to repeat assessments."


'''Additional resources''':
A provider of telecommunications service shall ensure that the service is accessible to and usable by individuals with disabilities, if readily achievable.
* [https://csrc.nist.gov/publications/detail/sp/800-115/final NIST Special Publications 800-115], pages 6-5 and 6-6
* No LIMSpec comp (organizational policy rather than system specification)


====CA-3 System interconnections====
'''(d) Compatibility'''
This control recommends the organization should explicitly authorize, document, review, and update interconnection security agreements (ISA) or system-based security plans, as they relate to the interconnection of information systems in the organization. Separately, in NIST SP 800-47, at D-1, NIST defines an ISA an an established agreement between owner-operators of connected IT systems to document and agree to the technical requirements associated with any interconnections between the organizations' systems. However, NIST notes, "[i]f interconnecting systems have the same authorizing official, organizations do not need to develop interconnection security agreements. Instead, organizations can describe the interface characteristics between those interconnecting systems in their respective security plans."
Whenever the requirements of subsections (b) and (c) are not readily achievable, such a manufacturer or provider shall ensure that the equipment or service is compatible with existing peripheral devices or specialized customer premises equipment commonly used by individuals with disabilities to achieve access, if readily achievable.</blockquote>


'''Additional resources''':
The term '''disability''' is [https://www.law.cornell.edu/uscode/text/42/12102 defined here]. You can read the full entry, but the basics are:
* [https://csrc.nist.gov/publications/detail/sp/800-47/final NIST Special Publications 800-47]
* [https://csrc.nist.gov/publications/detail/sp/800-100/final NIST Special Publications 800-100], pages 46–58
* No LIMSpec comp (organizational policy rather than system specification)


====CA-5 Plan of action and milestones====
<blockquote>'''(1) Disability''' The term “disability” means, with respect to an individual—
This control recommends the organization develop and update a security authorization-related plan of action and milestones for the documentation of planned remedial actions and vulnerability resolutions. These key security authorization documents should be reviewed and updated at a defined frequency, based off the results of security control assessments, security impact analyses, and continuous monitoring results.
:'''(A)''' a physical or mental impairment that substantially limits one or more major life activities of such individual;


'''Additional resources''':
:'''(B)''' a record of such an impairment; or
* [https://csrc.nist.gov/publications/detail/sp/800-37/rev-1/final NIST Special Publications 800-37, Rev. 1]
* No LIMSpec comp (organizational policy rather than system specification)


====CA-6 Security authorization====
:'''(C)''' being regarded as having such an impairment (as described in paragraph (3)).</blockquote>
This control recommends the organization assign a manager or member of senior leadership as an "authorizing official" that essentially approves the system to be put into operation based on the results of security assessments and accepts responsibility for the risks associated with operation. The authorization should also be updated at a defined frequency. It's important to note that this control is described by NIST as being an "inherently federal responsibility and therefore, authorizing officials must be federal employees." If applying this control to non-federal systems, there is still plenty of sense in designating a key individual in the organization as responsible for making the call post-security assessment of allowing the system to go live, as well as accepting the risks of putting the system into operation. The same principle can be applied to major security upgrades and reconfiguration of existing systems.


'''Additional resources''':
The term '''readily achievable''' is [https://www.law.cornell.edu/uscode/text/42/12181 defined here]. It is defines as:
* [https://csrc.nist.gov/publications/detail/sp/800-37/rev-1/final NIST Special Publications 800-37, Rev. 1]
* [https://csrc.nist.gov/publications/detail/sp/800-137/final NIST Special Publications 800-137]
* No LIMSpec comp (organizational policy rather than system specification)


====CA-7 Continuous monitoring====
<blockquote>'''(9) Readily achievable''' The term “readily achievable” means easily accomplishable and able to be carried out without much difficulty or expense. In determining whether an action is readily achievable, factors to be considered include—
This control recommends the organization develop a continuous monitoring program and implementation strategy. The program should define the metrics required for organizational performance indicators, as well as how often those metrics are applied and assessed for functionality and sufficiency. How the information is analyzed and correlated, how the organization responds to those activities, and how they are reported (who and when) must also be addressed. Metrics should follow the SMART principle of being specific, measurable, actionable, relevant, and focused on a timely nature.


'''Additional resources''':
:'''(A)''' the nature and cost of the action needed under this chapter;
* [https://csrc.nist.gov/publications/detail/sp/800-37/rev-1/final NIST Special Publications 800-37, Rev. 1]
:'''(B)''' the overall financial resources of the facility or facilities involved in the action; the number of persons employed at such facility; the effect on expenses and resources, or the impact otherwise of such action upon the operation of the facility;
* [https://csrc.nist.gov/publications/detail/sp/800-39/final NIST Special Publications 800-39]
:'''(C)''' the overall financial resources of the covered entity; the overall size of the business of a covered entity with respect to the number of its employees; the number, type, and location of its facilities; and
* [https://csrc.nist.gov/publications/detail/sp/800-53a/rev-4/final NIST Special Publications 800-53A, Rev. 4]
:'''(D)''' the type of operation or operations of the covered entity, including the composition, structure, and functions of the workforce of such entity; the geographic separateness, administrative or fiscal relationship of the facility or facilities in question to the covered entity.</blockquote>
* [https://csrc.nist.gov/publications/detail/sp/800-115/final NIST Special Publications 800-115]
* [https://csrc.nist.gov/publications/detail/sp/800-137/final NIST Special Publications 800-137]
* No LIMSpec comp (organizational policy rather than system specification)


====CA-9 Internal system connections====
===2. Rehabilitation Act of 1973, Section 508, amended ([https://www.law.cornell.edu/uscode/text/29/794d 29 U.S.C. 794d] - Electronic and information technology)===
This control recommends the organization essentially create a systems map, documenting how the various parts of the system should interconnect—as well as the characteristics of the connection and the nature of the information transported through it—and explicitly authorizing the interconnection to occur. This includes connections through mobile devices, printers, computers, sensors, and servers. It may be useful to classify components of the system that have common characteristics or configurations to make authorizations (as classes) easier.


'''Additional resources''':
There's a government website dedicated to Section 508: [https://www.section508.gov/ https://www.section508.gov/] The related laws and polices can be [https://www.section508.gov/manage/laws-and-policies/ found here]. The intro states (italics emphasis mine):
* No LIMSpec comp (organizational policy rather than system specification)
 
<blockquote>In 1998, Congress amended the Rehabilitation Act of 1973 to require Federal agencies to make their electronic and information technology (EIT) accessible to people with disabilities. The law (29 U.S.C § 794 (d)) ''applies to all Federal agencies when they develop, procure, maintain, or use electronic and information technology''. Under Section 508, agencies must give ''disabled employees and members of the public'' access to information comparable to the access available to others.
 
The [https://www.access-board.gov/ U.S. Access Board] is responsible for developing Information and Communication Technology (ICT) accessibility ''standards'' to ''incorporate into regulations that govern Federal procurement practices.'' On January 18, 2017, the Access Board issued a final rule that updated accessibility requirements covered by Section 508, and refreshed guidelines for telecommunications equipment subject to Section 255 of the Communications Act. The final rule went into effect on January 18, 2018.
 
The rule updated and reorganized the Section 508 Standards and Section 255 Guidelines ''in response to market trends and innovations in technology.'' The refresh also harmonized these requirements with other guidelines and standards both in the U.S. and abroad, including standards issued by the European Commission, ''and with the World Wide Web Consortium (W3C) Web Content Accessibility Guidelines (WCAG 2.0), a globally recognized voluntary consensus standard for web content and ICT.''</blockquote>
 
In discussing ICT, the U.S. Access Board [https://www.access-board.gov/ict/#b-summary-of-key-provisions summarized the key provisions] as such:
 
<blockquote>The Revised 508 Standards and 255 Guidelines replace the current product-based regulatory approach with an approach based on ICT functions. The revised technical requirements, which are organized along the lines of ICT functionality, provide requirements to ensure that covered hardware, software, electronic content, and support documentation and services are accessible to people with disabilities. In addition, the revised requirements include functional performance criteria, which are outcome-based provisions that apply in two limited instances: when the technical requirements do not address one or more features of ICT or when evaluation of an alternative design or technology is needed under equivalent facilitation.</blockquote>
 
The full (lengthy) information about the ICT Accessibility 508 Standards and 255 Guidelines is found here: [https://www.access-board.gov/ict/ https://www.access-board.gov/ict/]
 
The specific software requirements that LabLynx will likely need to consider under Section 508 appear to be found in [https://www.access-board.gov/ict/#chapter-5-software Chapter 5: Software] and [https://www.access-board.gov/ict/#chapter-6-support-documentation-and-services Chapter 6: Support Documentation and Services]. (If for some reason LLX is in the hardware domain, they'll want to also consider[https://www.access-board.gov/ict/#chapter-4-hardware Chapter 4: Hardware] If you're curious about the underlying standards, you can find them in [https://www.access-board.gov/ict/#chapter-7-%C2%A0-referenced-standards Chapter 7: Referenced Standards].
 
Finally, the Section 508 government website has a full Design & Develop section that may be applicable to development process: [https://www.section508.gov/develop/ https://www.section508.gov/develop/]
 
==Additional information==
 
1. The Section 508 website and its glossary mention LIMS under "[https://www.section508.gov/art/glossary/#S scientific instrument]," though only secondarily. At the end: "If a scientific instrument is integrated with a computer or a monitor, the computer (and associated operating system) and the monitor would be separate EIT deliverables, requiring their own Government Product Accessibility Templates (GPAT). If the computer included application software, this software would be another EIT deliverable requiring its own GPAT."
2. It appears some software can qualify for "a legally-defined Exception (Back Office)," as found in this example with STARLIMS and the VA: [https://www.oit.va.gov/Services/TRM/ToolPage.aspx?tid=7502 https://www.oit.va.gov/Services/TRM/ToolPage.aspx?tid=7502]
 
3. Some additional posts and guides that may be revealing:
* [https://www.levelaccess.com/how-do-i-determine-if-my-web-site-or-application-is-section-508-compliant/ How do I determine if my website or application is Section 508 compliant?]
* [https://ftp.cdc.gov/pub/Software/RegistryPlus/508%20Compliance/508softwareandos.doc GSA Guide For Making Software Applications and Operating Systems Accessible] (.doc file; NOTE: No date, so not sure if incorporates amended material, so be careful)
* [https://www.dhs.gov/publication/dhs-section-508-compliance-test-processes DHS Section 508 Compliance Test Processes]

Latest revision as of 21:23, 28 February 2022

The laws themselves

1. Federal Telecommunications Act of 1996, Section 255 (47 U.S.C. § 255 - Access by persons with disabilities)

(b) Manufacturing

A manufacturer of telecommunications equipment or customer premises equipment shall ensure that the equipment is designed, developed, and fabricated to be accessible to and usable by individuals with disabilities, if readily achievable.

(c) Telecommunications services

A provider of telecommunications service shall ensure that the service is accessible to and usable by individuals with disabilities, if readily achievable.

(d) Compatibility

Whenever the requirements of subsections (b) and (c) are not readily achievable, such a manufacturer or provider shall ensure that the equipment or service is compatible with existing peripheral devices or specialized customer premises equipment commonly used by individuals with disabilities to achieve access, if readily achievable.

The term disability is defined here. You can read the full entry, but the basics are:

(1) Disability The term “disability” means, with respect to an individual—

(A) a physical or mental impairment that substantially limits one or more major life activities of such individual;
(B) a record of such an impairment; or
(C) being regarded as having such an impairment (as described in paragraph (3)).

The term readily achievable is defined here. It is defines as:

(9) Readily achievable The term “readily achievable” means easily accomplishable and able to be carried out without much difficulty or expense. In determining whether an action is readily achievable, factors to be considered include—

(A) the nature and cost of the action needed under this chapter;
(B) the overall financial resources of the facility or facilities involved in the action; the number of persons employed at such facility; the effect on expenses and resources, or the impact otherwise of such action upon the operation of the facility;
(C) the overall financial resources of the covered entity; the overall size of the business of a covered entity with respect to the number of its employees; the number, type, and location of its facilities; and
(D) the type of operation or operations of the covered entity, including the composition, structure, and functions of the workforce of such entity; the geographic separateness, administrative or fiscal relationship of the facility or facilities in question to the covered entity.

2. Rehabilitation Act of 1973, Section 508, amended (29 U.S.C. 794d - Electronic and information technology)

There's a government website dedicated to Section 508: https://www.section508.gov/ The related laws and polices can be found here. The intro states (italics emphasis mine):

In 1998, Congress amended the Rehabilitation Act of 1973 to require Federal agencies to make their electronic and information technology (EIT) accessible to people with disabilities. The law (29 U.S.C § 794 (d)) applies to all Federal agencies when they develop, procure, maintain, or use electronic and information technology. Under Section 508, agencies must give disabled employees and members of the public access to information comparable to the access available to others.

The U.S. Access Board is responsible for developing Information and Communication Technology (ICT) accessibility standards to incorporate into regulations that govern Federal procurement practices. On January 18, 2017, the Access Board issued a final rule that updated accessibility requirements covered by Section 508, and refreshed guidelines for telecommunications equipment subject to Section 255 of the Communications Act. The final rule went into effect on January 18, 2018.

The rule updated and reorganized the Section 508 Standards and Section 255 Guidelines in response to market trends and innovations in technology. The refresh also harmonized these requirements with other guidelines and standards both in the U.S. and abroad, including standards issued by the European Commission, and with the World Wide Web Consortium (W3C) Web Content Accessibility Guidelines (WCAG 2.0), a globally recognized voluntary consensus standard for web content and ICT.

In discussing ICT, the U.S. Access Board summarized the key provisions as such:

The Revised 508 Standards and 255 Guidelines replace the current product-based regulatory approach with an approach based on ICT functions. The revised technical requirements, which are organized along the lines of ICT functionality, provide requirements to ensure that covered hardware, software, electronic content, and support documentation and services are accessible to people with disabilities. In addition, the revised requirements include functional performance criteria, which are outcome-based provisions that apply in two limited instances: when the technical requirements do not address one or more features of ICT or when evaluation of an alternative design or technology is needed under equivalent facilitation.

The full (lengthy) information about the ICT Accessibility 508 Standards and 255 Guidelines is found here: https://www.access-board.gov/ict/

The specific software requirements that LabLynx will likely need to consider under Section 508 appear to be found in Chapter 5: Software and Chapter 6: Support Documentation and Services. (If for some reason LLX is in the hardware domain, they'll want to also considerChapter 4: Hardware If you're curious about the underlying standards, you can find them in Chapter 7: Referenced Standards.

Finally, the Section 508 government website has a full Design & Develop section that may be applicable to development process: https://www.section508.gov/develop/

Additional information

1. The Section 508 website and its glossary mention LIMS under "scientific instrument," though only secondarily. At the end: "If a scientific instrument is integrated with a computer or a monitor, the computer (and associated operating system) and the monitor would be separate EIT deliverables, requiring their own Government Product Accessibility Templates (GPAT). If the computer included application software, this software would be another EIT deliverable requiring its own GPAT."

2. It appears some software can qualify for "a legally-defined Exception (Back Office)," as found in this example with STARLIMS and the VA: https://www.oit.va.gov/Services/TRM/ToolPage.aspx?tid=7502

3. Some additional posts and guides that may be revealing: