...
Threat and Vulnerability Identification
(see Categories of Harm and Impact Definitions)
Vulnerability | Threat-source | Threat Action | Category of Harm | Likelihood of Occurrence | Impact of Harm | E-signature Cost Benefit Assessment |
|---|---|---|---|---|---|---|
System unavailability | Error, component failure, or act of God | Power failure, network failure, computer component failure, operator error, software failure, capacity constraint, etc. | Inconvenience, distress or damage to standing or reputation | Moderate: failures will happen, but competently managed systems typically have availability records of 99% or better | Low: for fishery management decision support typical availability is adequate. Even in the event of a systemic failure fishery management decision-making would continue and unavailability would be a short-term inconvenience. Smaller scale failures, for instance a failure that prevents reporting from one processor, would be a minor inconvenience. | N.A. (E-signature has no effect, positive or negative, on this vulnerability) N.A. (E-signature has no effect, positive or negative, on this vulnerability) |
System unavailability | Vandalism | Internet security exploit such as denial-of-service attack | Inconvenience, distress or damage to standing or reputation | Low: this is not an high-profile Internet system and should not be a particularly attractive target. Also, if necessary, the system could be hosted in a data center with an incident response capability that could deal with all but the most sophisticated attacks. | Low: even in the event of a systemic failure fishery management decision-making would continue and unavailability would be a short-term inconvenience | N.A. |
System misuse | System administrator, operator, or other agency user | Abuse of insider knowledge and access for unauthorized use or release of information | Civil or criminal violations | Low: agency staff have significant incentives to behave appropriately and periodic training in ethics and computer security | Moderate: at worst, a release of personal or commercially sensitive information to unauthorized parties resulting in loss of confidentiality with an expected serious adverse effect on organizational operations. | N.A. |
" | " | " | Civil or criminal violations | Low: agency staff have significant incentives to behave appropriately and periodic training in ethics and computer security | Moderate: at worst, a risk of civil or criminal violations that may be subject to enforcement efforts | N.A. |
System compromise | Vandal | Internet security exploit circumventing security controls | Unauthorized release of sensitive information | Low: agency staff use due diligence to secure systems and reduce vulnerabilities. Also this is not an high-profile Internet system and should not be a particularly attractive target. If necessary, the system could be hosted in a data center with an incident response capability that could deal with all but the most sophisticated attacks. | Moderate: at worst, a release of personal or commercially sensitive information to unauthorized parties resulting in loss of confidentiality with an expected serious adverse effect on organizational operations. | N.A. |
" | " | " | Civil or criminal violations | Low: agency staff use due diligence to secure systems and reduce vulnerabilities. Also this is not an high-profile Internet system and should not be a particularly attractive target. If necessary, the system could be hosted in a data center with an incident response capability that could deal with all but the most sophisticated attacks. | Moderate: at worst, a risk of civil or criminal violations that may be subject to enforcement efforts | N.A. |
Failure to report | Processor or processor in collusion with fisher | Processor fails to report, either through negligence, or with intent to mislead fisheries managers and evade fisheries management controls or enforcement actions | Harm to agency programs or public interests | Low: permitted parties know the rules and understand the risks of non-compliance | Moderate: most individual trip reports would be inconsequential in overall impact, but some would be consequential, and any widespread or long-term failure to report would facilitate overfishing. | Benefit: failure to report would be detectable quickly, resulting in more responsive enforcement and potentially a higher rate of compliance |
" | " | " | Civil or criminal violations | Low: permitted parties know the rules and understand the risks of non-compliance | Moderate: at worst, a risk of civil or criminal violations that may be subject to enforcement efforts | Benefit: failure to report would be detectable quickly, resulting in more responsive enforcement and potentially a higher rate of compliance |
Under-reporting or misreporting catch | Fisher and processor in collusion | Fisher and processor collude to under-report or misreport, to mislead fisheries managers and evade fisheries management controls | Harm to agency programs or public interests | Low: permitted parties have a lot to lose and there are enough checks and balances in the system to discourage fraud | Moderate: at worst, a serious adverse effect to public interests. For example, in a commercial landing the species could be misreported from an overfished species to a less restricted species to evade a fisheries closure action, with potentially significant damage to the overfished species, i.e., public interests | Benefit: e-reporting and e-signature can result in more immediate feedback for detectable errors, and more immediate feedback facilitates more accurate reporting |
" | " | " | Civil or criminal violations | Low: permitted parties have a lot to lose and there are enough checks and balances in the system to discourage fraud | Moderate: at worst, a risk of civil or criminal violations that may be subject to enforcement efforts | Benefit: misreporting problems might be detected quickly, resulting in more responsive enforcement and potentially a higher rate of compliance |
Impersonation in e-ticket transactions | Common criminal/identity thief | Impersonation using stolen identity credentials, to receive full market price for stolen fish | Inconvenience, distress or damage to standing or reputation | Low: e-ticket transactions take place in a context of fish delivery, and the fisher and processor are normally known to each other | Low: someone would be likely to notice and when detected, the impact could be effectively mitigated. The impact would be limited to the parties whose identity and fish have been stolen | No net cost or benefit: inconvenience, distress or damage is not significantly different in electronic transactions than it is in paper transactions |
" | " | " | Civil or criminal violations | Low: e-ticket transactions take place in a context of fish delivery, and the fisher and processor are normally known to each other | Moderate: at worst, a risk of civil or criminal violations that may be subject to enforcement efforts | Cost: criminal e-signature forgery, falsification or misrepresentation will provide new challenges for enforcement investigation and litigation |
Impersonation in e-ticket transactions | Competitor | Impersonation using stolen identity credentials, to sell fish without debiting own quota | Inconvenience, distress or damage to standing or reputation | Low: a competitor might have a motive, but is unlikely to have means or opportunity | Low: impersonated parties would be likely to notice and when detected, the impact could be effectively mitigated | No net cost or benefit: inconvenience, distress or damage is not significantly different in electronic transactions than it is in paper transactions |
" | " | " | Civil or criminal violations | Low: a competitor might have a motive, but is unlikely to have means or opportunity | Moderate: at worst, a risk of civil or criminal violations that may be subject to enforcement efforts | Cost: criminal e-signature forgery, falsification or misrepresentation will provide new challenges for enforcement investigation and litigation |
Repudiation to escape accountability | Customer (fisher or processor) | Signer claims "I didn't sign that" | Civil or criminal violations | Low: in most cases a customer who repudiated an e-ticket document submission could then be prosecuted for fishing or processing without meeting record-keeping and reporting obligations. There will generally be independent evidence of the fishing or processing activity (follow the fish.) | Low: agency might expend effort to resolve, but the distress would be limited and short-term | Cost: despite e-signature's legal standing and agency instructions, there is likely to be a tendency to regard a holographic signature as more significant or more binding. It is likely that the requirement to sign a filing with a holographic signature has more influence on the signer's behavior with respect to their consideration of what they are submitting, their commitment to reporting the truth, and their expectation of being held accountable. Persons signing with an e-signature are likely to understand that it would be difficult to prove what individual executed the e-signature (because credentials are transferable). This is likely to motivate some people to repudiate their e-signature if they are being held accountable for something signed with an e-signature. |
" | " | " | Civil or criminal violations | Low: in most cases a customer who repudiated an e-ticket document submission could then be prosecuted for fishing or processing without meeting record-keeping and reporting obligations. There will generally be independent evidence of the fishing or processing activity (follow the fish.) | Moderate: at worst, a risk of civil or criminal violations that may be subject to enforcement efforts | Cost: criminal e-signature forgery, falsification or misrepresentation will provide new challenges for enforcement investigation and litigation |
Categories of Harm and Impact Definitions for reference
HARM | LOW IMPACT | MODERATE IMPACT | HIGH IMPACT |
|---|---|---|---|
Inconvenience, distress, or damage to standing or reputation | at worst, limited, short-term inconvenience, distress or embarrassment to any party | at worst, serious short term or limited long-term inconvenience, distress or damage to the standing or reputation of any party | severe or serious long-term inconvenience, distress or damage to the standing or reputation of any party (ordinarily reserved for situations with particularly severe effects or which affect many individuals) |
Financial loss | at worst, an insignificant or inconsequential unrecoverable financial loss to any party | at worst, a serious unrecoverable financial loss to any party | severe or catastrophic unrecoverable financial loss to any party |
Agency liability | at worst, an insignificant or inconsequential agency liability | at worst, a serious agency liability | severe or catastrophic agency liability |
Harm to agency programs or public interests | at worst, a limited adverse effect on organizational operations or assets, or public interests. Examples of limited adverse effects are: (1) mission capability degradation to the extent and duration that the organization is able to perform its primary functions with noticeably reduced effectiveness, or (2) minor damage to organizational assets or public interests | at worst, a serious adverse effect on organizational operations or assets, or public interests. Examples of serious adverse effects are: (1) significant mission capability degradation to the extent and duration that the organization is able to perform its primary functions with significantly reduced effectiveness; or (2) significant damage to organizational assets or public interests | a severe or catastrophic adverse effect on organizational operations or assets, or public interests. Examples of severe or catastrophic effects are: (1) severe mission capability degradation or loss of to the extent and duration that the organization is unable to perform one or more of its primary functions; or (2) major damage to organizational assets or public interests |
Unauthorized release of sensitive information | at worst, a limited unauthorized release of personal, U.S. government sensitive, or commercially sensitive information to unauthorized parties resulting in a loss of confidentiality with an expected limited adverse effect on organizational operations, organizational assets, or individuals | at worst, a release of personal, U.S. government sensitive, or commercially sensitive information to unauthorized parties resulting in loss of confidentiality with an expected serious adverse effect on organizational operations, organizational assets, or individuals. | a release of personal, U.S. government sensitive, or commercially sensitive information to unauthorized parties resulting in loss of confidentiality with an expected severe or catastrophic adverse effect on organizational operations, organizational assets, or individuals |
Harm to personal safety | at worst, minor injury not requiring medical treatment | at worst, moderate risk of minor injury or limited risk of injury requiring medical treatment | a risk of serious injury or death |
Civil or criminal violations | at worst, a risk of civil or criminal violations of a nature that would not ordinarily be subject to enforcement efforts | at worst, a risk of civil or criminal violations that may be subject to enforcement efforts | a risk of civil or criminal violations that are of special importance to enforcement programs |