DOT's Cloud-Based Systems' Security Weaknesses Hinder Its Transition to a Zero Trust Architecture

Develop and implement policies and procedures governing DOT components and Operating Administrations' adoption and use of cloud services for their cloud-based system and at a minimum require system owners to: a. Submit an Authorization to Operate letter to the Federal Risk and Authorization Management Program (FedRAMP) Program Management Office before adopting and using cloud services to ensure (1) cloud services comply with FedRAMP security baselines, and (2) FedRAMP has an accurate inventory of DOT cloud services and cloud service providers. b. Conduct a quality and risk review of the Department's cloud service providers cloud service offering authorization package to ensure that it clearly and accurately reflects the cloud service offering's security posture so DOT's Authorizing Official can make an informed risk-based authorization decision, as required by FedRAMP. c. Include in its executive summary/Authorization to Operate letter to the Authorizing Official proof of its review of the respective cloud service providers' continuous monitoring activities to ensure their cloud systems' security posture remains sufficient for their own use and supports ongoing authorization as required by FedRAMP.

Working with the appropriate DOT procurement officials for FAA, FMCSA, FHWA, MARAD, FRA, NHTSA, PHMSA, and OST, set up service level agreements as required, with each of their cloud service providers to define and set agency expectations and cloud service provider-specific responsibilities.

Develop and implement a process that enables FAA's Security Operations Center to receive the necessary log data for ensuring proper cybersecurity incident monitoring for all departmental cloud-based systems.

Direct and require confirmation of completion from OST's cloud-based system owner for the Federal Human Resources Navigator-Software-as-a-Service to: a. Include in its executive summary/Authorization to Operate letter to the Authorizing Official proof of its review of cloud service provider's continuous monitoring activities to ensure its cloud system security posture remains sufficient for its own use and supports its ongoing authorization as required by FedRAMP. b. Use personal identity verification cards as the primary authentication mechanism to ensure secure system login. c. Develop a Privacy Impact Analysis to help identify and manage personally identifiable information and privacy risks. d. Identify a security official to review system audit log files. e. Develop and implement a process to remove extracted data containing sensitive information within 90 days of extraction in accordance with DOT requirements.

Direct and require confirmation of completion from OST's cloud-based system owner for the Data Analysis Visualization Environment-Software-as-a-Service to: a. Include in its executive summary/Authorization to Operate letter to the Authorizing Official proof of its review of cloud service provider's continuous monitoring activities to ensure its cloud system security posture remains sufficient for its own use and supports its ongoing authorization, as required by FedRAMP. b. Develop and implement a process to conduct monthly vulnerability scans as required by DOT.

Direct and require confirmation of completion from FRA's cloud-based system owner for its Cloud Application Services-Software-as-a-Service-to: a. Include in its executive summary/Authorization to Operate letter to the Authorizing Official proof of its review of cloud service provider's continuous monitoring activities to ensure its cloud system security posture remains sufficient for its own use and supports its ongoing authorization as, required by FedRAMP. b. Update the Privacy Impact Analysis for the Railroad Compliance System to ensure the proper privacy controls are in place to identify and protect personally identifiable information and other sensitive information.

Direct and require confirmation of completion from PHMSA's cloud-based system owner for the Pipeline Risk Management Information System-Infrastructure-as-a-service-and PHMSA Data Mart-Infrastructure-as-a-service to: a. Include in its executive summary/Authorization to Operate letter to the Authorizing Official proof of its review of cloud service provider's continuous monitoring activities to ensure its cloud system security posture remains sufficient for its own use and supports its ongoing authorization as FedRAMP requires for Pipeline Risk Management Information System. b. Include in its executive summary/Authorization to Operate letter to the Authorizing Official proof of its review of cloud service provider's continuous monitoring activities to ensure its cloud system security posture remains sufficient for its own use and supports its ongoing authorization as FedRAMP requires for PHMSA Data Mart.

Direct and require confirmation of completion from FRA's cloud-based system owner for the Multiple Case Incident Analysis-Infrastructure-as-a-service to include in its executive summary/Authorization to Operate letter to the Authorizing Official proof of its review of cloud service provider's continuous monitoring activities to ensure its cloud system security posture remains sufficient for its own use and supports its ongoing authorization, as required by FedRAMP.

Direct and require confirmation of completion from FAA's cloud-based system owner for the FAA Cloud Services-Infrastructure-as-a-service and Platform-as-a-Service to: a. Incorporate flaw remediation into ongoing configuration management processes. b. Develop and implement a process to regularly manage malicious code protection to detect and eradicate malicious code at the entry point for its Infrastructure-as-a-service and Platform-as-a-Service. c. Develop and implement a change control process and use baseline configuration settings and document configuration settings to establish a basis for future builds, releases, and/or changes. d. Develop and implement a process to perform an automated review of network accounts or implement an alternative method for identifying users on the network in real-time. e. Develop and implement a process to require the most current cryptographic mechanisms to protect data during network transmission to provide complete boundary protection and reduce the risk of compromise. f. Develop and implement a process to encrypt data transmitted within the Infrastructure-as-a-service environment to reduce the risk of compromise and data exposure. g. Develop and implement a process to review vulnerability scans results and remediate vulnerabilities within specified timeframes as required by FAA's security handbook.