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Compliance Policy


Approved Date – 02/22/2021
Published Date – 02/22/2021
Revised Date – 05/25/2021

 

1. Purpose

The purpose of this policy is to establish a consistent and effective framework for monitoring, measurement, and analysis of compliance with information security policies, standards, and procedures, as well as the performance and the effectiveness of the Cyber Security Framework (CSF). Furthermore, this policy concerns itself with avoidance of legal, statutory, regulatory, or contractual obligation breaches related to information. 

2. Authority

DC Official Code § 1-1401 et seq., provides the Office of the Chief Technology Officer (“OCTO”) with the authority to provide information technology (IT) services, write and enforce IT policies, and secure the network and IT systems for the District government. This document can be found at: https://code.dccouncil.us/dc/council/code/sections/1-1402.html.

3. Applicability

This policy applies to all District workforce members performing official functions on behalf of the District Government, and/or any District agency/District/entity who receive enterprise services from OCTO. In addition, this policy applies to any providers and third-party entities with access to District information, networks, and applications.

4. Policy

4.1. Monitoring, measurement, analysis and evaluation

All District agencies must evaluate the information security performance and the effectiveness of the information security controls.

All District agencies must determine: 

4.1.1.  What needs to be monitored and measured, including information security processes and controls.
4.1.2.  The methods for monitoring, measurement, analysis, and evaluation, as applicable, ensure valid results.
4.1.3.  When the monitoring and measuring must be performed.
4.1.4.  The employee is responsible for conducting the monitoring and measurement for compliance.
4.1.5.  When the results from monitoring and measurement must be analyzed and evaluated.
4.1.6.  Who must analyze and evaluate these results.

All District agencies must retain appropriate documented information as evidence of the monitoring and measurement results.

4.2. Internal audit/Independent Reviews

4.2.1. All District agencies must conduct internal audits annually at the minimum or when significant changes occur to provide information on whether the information security controls conform to the District own requirements as stipulated by its IT Security Policies, regulatory requirements, Legal obligations through existing contracts, and the NIST 800-53 Rev 5 framework.

4.2.2. The independent reviews must include controls, policies, processes and procedures for information security.

4.3. Information systems audit controls

Audit requirements and activities involving verification of operational systems must be carefully planned and agreed to minimize disruptions to business processes.

4.4. Management review

The District CISO must review all District Policies annually to ensure its continuing suitability, adequacy, and effectiveness. The review must include consideration of:

The status of actions from previous reviews.

4.4.1.  Changes in external and internal issues that are relevant to the security policies.
4.4.2.  Feedback on the information security performance, including trends in nonconformities and corrective actions, monitoring and measurement results, audit results, and fulfillment of information security objectives.
4.4.3.  Feedback from interested parties.
4.4.4.  Results of risk assessment and status of the risk treatment plan.
4.4.5.  Opportunities for continual improvement.

The outputs of the CISO review must include decisions related to continual improvement opportunities and any needs for changes to the District Information Security program. 

The CISO must retain documented information as evidence of the results of reviews. 

4.5. Compliance with security policies and standards

System Managers must regularly review the compliance of information processing and procedures (SOPs) within their area of responsibility with the appropriate security policies, standards, and any other security requirements. 

4.6. Technical compliance review

Information systems must be regularly reviewed for compliance with the District information security policies and standards. 

4.7. Noncompliance and corrective action

Corrective actions must be appropriate to the effects of the nonconformities encountered. When Noncompliance occurs, the District agencies must:

4.7.1.  React to the noncompliance and as applicable take action to control and correct it and deal with the consequences.
4.7.2.  Evaluate the need for action to eliminate the causes of non-compliance, so that it does not recur or occur elsewhere, by:

  • Reviewing the noncompliance.
  • Determining the causes of the Noncompliance.
  • Determining if similar non-compliance exist or could potentially occur.
  • Implement any action needed.
  • Review the effectiveness of any corrective action taken.
  • Make changes to the information security management system, if necessary.

The District agencies must retain documented information as evidence of:

  1. The nature of the noncompliance and any subsequent actions taken.
  2. The results of any corrective action taken.

4.8. Continuous Improvement

All District agencies must continually improve the suitability, adequacy and effectiveness of the information security management system.

5. Exemptions

Exceptions to this policy shall be requested in writing to the Agency’s CIO and the request will be escalated to the OCTO Chief Information Security Officer (“CISO”) for approval.

6. Definitions

The definition of the terms used in this document can be found in the Policy Definitions website.