E-signature Evaluation
Business Context, Transaction Types and Volume
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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 |
E-signature Risk Mitigation
Risk Mitigation Analysis Worksheet (per procedural directive page 9)
Impact Categories | Significant | Impact | Assurance Level |
|---|---|---|---|
Inconvenience, distress or damage to standing or reputation | No | Mod | 2/3 |
Financial loss or agency liability | No | Mod | 2/3 |
Agency liability | No | Mod | 2/3 |
Harm to agency programs or public interests | No | Low | 2 |
Unauthorized release of sensitive information | No | Low | 2 |
Personal Safety | N/A | N/A | |
Civil or criminal violations | No | Moderate | 3 |
Appropriate OMB Assurance Level to Mitigate Business Risk
Lowest Assurance Level that Mitigates All Impact Categories | Mitigating Controls | Appropriate Assurance Level with Consideration of Mitigating Controls | Proposed E-signature Alternative |
|---|---|---|---|
Level 3---...appropriate for transactions needing high confidence in the asserted identity's accuracy. People may use Level 3 credentials to access restricted web services without the need for additional identity assertion controls. | Multiple sources of information, some with counter-balancing incentives. | Level 2---On balance, confidence exists that the asserted identity is accurate. Level 2 credentials are appropriate for a wide range of business with the public where agencies require an initial identity assertion (the details of which are verified independently prior to any Federal action). | NPS-like |