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. Agency staff use due diligence to secure systems and reduce vulnerabilities, including daily data backups, etc. | Low: permit processing is not a time-critical operation, and a paper-based alternative will continue to be an option. Even a systemic failure would be a short-term inconvenience. Smaller scale failures, for instance a failure that prevents online access for one user, would be a minor inconvenience. | N.A. (E-signature has no effect, positive or negative, on this vulnerability) |
" | Vandal | 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 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 | Unauthorized release of sensitive information | 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. For example, all internet traffic with the system is conducted over a secure (SSL) connection. 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 permit | Customer (fisher or processor) | Fisher or processor fails to acquire required permits prior to participating in regulated activities | Harm to agency programs or public interests | Low: commercial fishers and processors know the rules and understand the risks of non-compliance, and the extensive mitigating controls make it difficult to initiate and maintain a commercial operation "below the radar" | Moderate: fishing or processing without agency oversight may facilitate overfishing with significant damage to public interests | N.A. |
Impersonation in registration and/or transactions | Common criminal/identity thief | Impersonation using stolen identity credentials, with fraudulent application, renewal or transfer | Inconvenience, distress or damage to standing or reputation | Low: it would be difficult to initiate and maintain a fraud when there are so many mitigating controls including business licenses, vessel registrations, proof of prior participation in fisheries, and transactions with other permitted parties | Low: impersonated parties would be likely to notice and when detected, the impact could be effectively mitigated | Cost: e-reporting and e-signature present a broader attack surface making impersonation more likely |
" | " | " | Unauthorized release of sensitive information | Low: successful identity theft could result in compromise of sensitive information from the victim's permit records | Low: there isn't a great deal of sensitive information in permit records, and the impact would be limited to the party whose identity has been stolen | Cost: e-reporting and e-signature present a broader attack surface making impersonation more likely |
Impersonation in registration and/or transactions | Disgruntled industry employee or competitor | Impersonation using stolen identity credentials, with fraudulent renewal or transfer, resulting in unwarranted suspension or revocation of an otherwise valid permit | Financial loss | Low: it would be difficult to initiate and maintain a fraud when there are so many mitigating controls including business licenses, vessel registrations, proof of prior participation in fisheries, and transactions with other permitted parties | Moderate: at worst, a serious unrecoverable financial loss to a permit holder, if the event caused an unwarranted suspension or revocation of an otherwise valid permit, and the victim was forced to forgo opportunity to participate in a fishery | No net cost or benefit: vulnerability for an attack by a well-informed party is not significantly different in electronic transactions than it is in paper transactions |
" | " | Impersonation using stolen identity credentials, with fraudulent submission with intent to incriminate or defame victim | Inconvenience, distress or damage to standing or reputation | Low: it would be difficult to initiate and maintain a fraud when there are so many mitigating controls including business licenses, vessel registrations, proof of prior participation in fisheries, and transactions with other permitted parties | Low: impersonated parties would be likely to notice and when detected, the impact could be effectively mitigated | No net cost or benefit: vulnerability for an attack by a well-informed party is not significantly different in electronic transactions than it is in paper transactions |
" | " | " | Unauthorized release of sensitive information | Low: the employee with the means and opportunity already has access to sensitive information and is unlikely to find anything more interesting in permit data | Low: there isn't a great deal of sensitive information in permit records, and the impact would be limited to the party whose identity has been stolen | Cost: e-reporting and e-signature present a broader attack surface making impersonation more likely. Note the increased vulnerability to impersonation when the objective is to retrieve sensitive information, which may involve fewer mitigating controls, and less vulnerability when the objective is to apply for permits or transfer permits, where supporting documentation is usually involved. |
" | Common criminal/identity thief | Impersonation using stolen identity credentials | Civil or criminal violations | Low: it would be difficult to initiate and maintain a fraud when there are so many mitigating controls including business licenses, vessel registrations, proof of prior participation in fisheries, and transactions with other permitted parties | 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" | Inconvenience, distress or damage to standing or reputation | Low: in most cases a customer who repudiated an e-signed document submission could then be prosecuted for fishing or processing without proper permits. 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-signed document submission could then be prosecuted for fishing or processing without proper permits. 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 |