E-signature Evaluation
Business Context, Transaction Types and Volume
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Business Risk in the Permit Context
NIST 800-30: Risk Management Guide for Information Technology Systems defines risk as a function of the likelihood of a given threat-source's exercising a particular potential vulnerability, and the resulting impact of that adverse event on the organization. The threat and vulnerability identification process that follows is based on NIST 800-30.
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Users and functionality
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The longline fleet has some technologically advanced vessels in the 65-70 foot range, but also some small vessels, perhaps as small as sixteen feet, fishing with rod and reel and potentially no technology aboard. The current conceptual design anticipates vessels hosting e-logbook software on a PC onboard the vessel and reporting as required (at the end of a day or trip) via email from the vessel, or alternatively, reporting by email from home after completion of a day-trip. (Combinations might be accommodated; perhaps capturing the data on a PC, saving it to portable media such as a memory stick, taking the memory stick home after the day-trip, and transmitting the file from home via email.)
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Data sensitivity and security
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Information collected pursuant to requirements of the MSA, including permit application information, is protected by its confidentiality provisions at § 402 and under its implementing regulations at 50 CFR Part 600 Subpart E, including NOAA Administrative Order (NAO) 216-100. Additional protections of the Privacy Act and FOIA apply to such data as well as those collected under the Halibut Act.
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Mitigating controls
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Perhaps the most significant mitigating control is that in commercial fisheries transactions, both parties to the transaction (typically the fisher and the fish processor) are permitted entities and each has some responsibility for accurate and complete record-keeping and reporting (for example, the fisher may be required to keep a logbook showing fishing efforts and catch, while the processor is required to report fish purchased). In these transactions it is typical for the parties to the transactions to have opposite and balancing interests (for example, when a fisher is selling fish to a processor, the fisher Considerations of business risk may benefit from categorization according to FIPS 199 which provides a common framework for expressing information security concerns throughout the federal government. This system has a FIPS 199 security categorization as follows:
- Low confidentiality requirements -- loss of confidentiality would be expected to have a limited adverse effect on organizational operations, assets, or individuals. A breach of confidentiality would damage our relationship with our constituency and could impact our ability to collect accurate data with which to manage fisheries. This could cause a degradation in mission capability to an extent and duration that the organization is able to perform its primary functions, but the effectiveness of the functions is noticeably reduced. It could also expose us to litigation and professional disrepute.
- Moderate integrity requirements -- among other things data from this system could be used to establish individual fishing quotas based on historical participation in a fishery. Individual fishing quotas have value, and it is critical to maintain access controls, change tracking, and auditability. The moderate level is specified to recognize that loss of integrity could result in significant financial harm to individuals.
- Low availability requirements -- a temporary loss of availability would be expected to have a limited adverse effect. Transactions dependent on this data are not particularly time-sensitive, and business requirements could be met via manual methods during a temporary system outage.
NIST 800-30: Risk Management Guide for Information Technology Systems defines risk as a function of the likelihood of a given threat-source's exercising a particular potential vulnerability, and the resulting impact of that adverse event on the organization. The threat and vulnerability identification process that follows is based on NIST 800-30.
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Users and functionality
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The longline fleet has some technologically advanced vessels in the 65-70 foot range, but also some small vessels, perhaps as small as sixteen feet, fishing with rod and reel and potentially no technology aboard. The current conceptual design anticipates vessels hosting e-logbook software on a PC onboard the vessel and reporting as required (at the end of a day or trip) via email from the vessel, or alternatively, reporting by email from home after completion of a day-trip. (Combinations might be accommodated; perhaps capturing the data on a PC, saving it to portable media such as a memory stick, taking the memory stick home after the day-trip, and transmitting the file from home via email.)
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Data sensitivity and security
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Information collected pursuant to requirements of the MSA, including permit application information, is protected by its confidentiality provisions at § 402 and under its implementing regulations at 50 CFR Part 600 Subpart E, including NOAA Administrative Order (NAO) 216-100. Additional protections of the Privacy Act and FOIA apply to such data as well as those collected under the Halibut Act.
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Mitigating controls
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Perhaps the most significant mitigating control is that in commercial fisheries transactions, both parties to the transaction (typically the fisher and the fish processor) are permitted entities and each has some responsibility for accurate and complete record-keeping and reporting (for example, the fisher may be required to keep a logbook showing fishing efforts and catch, while the processor is required to report fish purchased). In these transactions it is typical for the parties to the transactions to have opposite and balancing interests (for example, when a fisher is selling fish to a processor, the fisher wants the amount paid to be high, while the processor wants the amount paid to be low). These multiple sources of information and counter-balanced incentives tend to make deception more difficult to initiate and sustain.
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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 | |||
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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 vessel, 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 |
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 online Internet-exposed system and should have very low vulnerability to network-based exploits. | 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 N.A. 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. | |||
Failure to report | Fisher | Fisher fails to report, either through negligence, or with intent to mislead fisheries managers and evade fisheries management control or enforcement actions | Harm to agency programs or public interests | Low: permitted fishers know the rules and understand the risks of non-compliance | Moderate: any individual trip report would be inconsequential in overall impact, but widespread and long-term failure to report may facilitate overfishing . with significant damage to public interests | Benefit: failure to report would be detectable quickly, resulting in more responsive enforcement and potentially a higher rate of compliance. Also e-reporting and e-signature can be additional features of fishing activity management software, providing e-logbook reporting in a value-added context, potentially making compliance more attractive providing e-logbook reporting in a value-added context, potentially making compliance more attractive | " | " | |
" | " | " | Civil or criminal violations | Low: permitted fishers 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. Also e-reporting and e-signature can be additional features of fishing activity management software, providing e-logbook reporting in a value-added context, potentially making compliance more attractive. | |||
Under-reporting or misreporting catch | Fisher | Fisher under-reports or misreports, to mislead fisheries managers and evade fisheries management controls | Harm to agency programs or public interests | Low: permitted fishers know the rules and understand the risks of non-compliance | Low: any individual trip report with highly unlikely numbers would trigger data quality checks and would be corrected or disregarded. Credible individual trip reports, even if intentionally misreported, would be inconsequential in overall impact. Even a concerted long-term effort to misreport by any one fisher is likely to be either not creditable or inconsequential. | 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 fishers 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: misreporting problems might be detected quickly, resulting in more responsive enforcement and potentially a higher rate of compliance. | |||
Impersonation in e-logbook transactions | Common criminal/identity thief | Impersonation using stolen identity credentials, with fraudulent reporting of false data to incriminate or defame victim | Inconvenience, distress or damage to standing or reputation | Low: common criminals are unlikely to have subject-area expertise to discover an incrimination or defamation opportunity and there are probably easier attacks | Low: impersonated parties or agency staff would be likely to notice during dockside interview process and/or subsequent data review, and when detected, the impact could be effectively mitigated | No net cost or benefit: e-reporting and e-signature provide two layers of security controls (access controls on the vessel's computer, and access controls on the e-logbook software); the traditional paper logbook may have been laying about on the bridge with no security control. However, this may be balanced by the fact that it is easy to understand and mitigate the risk with the traditional paper logbook (the skipper will understand the risk and the potential solutions), while the risks associated with electronic solutions won't be well understood. | |||
" | " | Impersonation using stolen identity credentials, for access to sensitive information | Unauthorized release of sensitive information | Low: successful identity theft could result in compromise of sensitive information from the victim's logbook records but an uninformed criminal would be unlikely to find or identify sensitive information | Low: probably the only information of value that is credibly at risk is catch location, timing, and gear, and the people with the means to take advantage of that unique information are already well placed to have that same knowledge or to acquire it by closely observing the victim's fishing activity. Also, the impact would be limited to the party whose identity has been stolen | No net cost or benefit: e-reporting and e-signature provide two layers of security controls (access controls on the vessel's computer, and access controls on the e-logbook software); the traditional paper logbook may have been laying about on the bridge with no security control. However, this may be balanced by the fact that it is easy to understand and mitigate the risk with the traditional paper logbook (the skipper will understand the risk and the potential solutions), while the risks associated with electronic solutions won't be well understood. | |||
Impersonation in e-logbook transactions | Disgruntled industry employee | Impersonation using stolen identity credentials, with fraudulent reporting of false data to incriminate or defame victim | Inconvenience, distress or damage to standing or reputation | Low: opportunity will be limited because the e-logbook is onboard the vessel at sea and protected by two layers of security controls (access controls on the vessel's computer, and access controls on the e-logbook software); however, an employee might be more likely than others to have the means, motive, and opportunity | Low: impersonated parties or agency staff would be likely to notice during dockside interview process and/or subsequent data review, and when detected, the impact could be effectively mitigated | No net cost or benefit: vulnerability for an employee attack is not significantly different in electronic transactions than it is in paper transactions | |||
" | " | Impersonation using stolen identity credentials, for access to sensitive information | Unauthorized release of sensitive information | Low: the employee who might possibly have the means and opportunity already has access to sensitive information and is unlikely to find anything more interesting in e-logbook data | Low: probably the only information of value that is credibly at risk is catch location, timing, and gear, and the disgruntled employee is likely to already have that information from personal observation. Also, the impact would be limited to the party whose identity has been stolen | No net cost or benefit: vulnerability for an employee attack is not significantly different in electronic transactions than it is in paper transactions | |||
Impersonation in e-logbook transactions | Competitor | Impersonation using stolen identity credentials, with fraudulent reporting of false data to incriminate or defame victim | Inconvenience, distress or damage to standing or reputation | Low: a competitor might have a motive, but is unlikely to have means and opportunity | Low: impersonated parties or agency staff would be likely to notice during dockside interview No net cost or benefit: vulnerability for an employee attack is not significantly different in electronic transactions than it is in paper transactions process and subsequent data review, and when detected, the impact could be effectively mitigated | No net cost or benefit: e-reporting and e-signature provide two layers of security controls (access controls on the vessel's computer, and access controls on the e-logbook software); the traditional paper logbook may have been laying about on the bridge with no security control. However, this may be balanced by the fact that it is easy to understand and mitigate the risk with the traditional paper logbook (the skipper will understand the risk and the potential solutions), while the risks associated with electronic solutions won't be well understood. | |||
" | " | Impersonation using stolen identity credentials, for access to sensitive information | Unauthorized release of sensitive information | Low: a competitor might have a motive, but is unlikely to have means and opportunity | Low: probably the only information of value that is credibly at risk is catch location, timing, and gear, and the people with the means to take advantage of that unique information are already well placed to have that same knowledge or to acquire it by closely observing the victim's fishing activity. Also, the impact would be limited to the party whose identity has been stolen | No net cost or benefit: e-reporting and e-signature provide two layers of security controls (access controls on the vessel's computer, and access controls on the e-logbook software); the traditional paper logbook may have been laying about on the bridge with no security control. However, this may be balanced by the fact that it is easy to understand and mitigate the risk with the traditional paper No net cost or benefit: e-reporting and e-signature provide two layers of security controls (access controls on the vessel's computer, and access controls on the e-logbook software); the traditional paper logbook may have been laying about on the bridge with no security control. However, this may be balanced by the fact that it is easy to understand and mitigate the risk with the traditional paper logbook (the skipper will understand the risk and the potential solutions), while the risks associated with logbook (the skipper will understand the risk and the potential solutions), while the risks associated with electronic solutions won't be well understood. | |||
" | Common criminal/identity thief | Impersonation using stolen identity credentials | Civil or criminal violations | Low: opportunity will be limited because the e-logbook is onboard the vessel at sea and protected by two layers of security controls (access controls on the vessel's computer, and access controls on the e-logbook software) | 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) | 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-logbook document submission could then be prosecuted for fishing without following record-keeping and reporting requirements. 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-logbook document submission could then be prosecuted for fishing without following record-keeping and reporting requirements. 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
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HARM
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LOW IMPACT
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MODERATE IMPACT
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E-signature Risk Mitigation
Risk Mitigation Analysis Worksheet (per procedural directive page 9)
Impact Categories | Significant | Impact | Assurance Level | ||
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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 No net cost or benefit: e-reporting and e-signature provide two layers of security controls (access controls on the vessel's computer, and access controls on the e-logbook software); the traditional paper logbook may have been laying about on the bridge with no security control. However, this may be balanced by the fact that it is easy to understand and mitigate the risk with the traditional paper logbook (the skipper will understand the risk and the potential solutions), while the risks associated with electronic solutions won't be well understood. 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 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 to attempt to escape accountability. 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 No | Low | 1 |
Financial loss or agency liability | N/A | N/A | |||
Agency liability | N/A | N/A | |||
Harm to agency programs or public interests | No | Moderate | 3 | ||
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 |
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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). |