February 1, 2013 - The Federal Communications Commission (FCC) did not effectively implement appropriate information security controls in the initial components of the Enhanced Secured Network (ESN) project.
Although FCC took steps to enhance its ability to control and monitor its network for security threats, weaknesses identified in the commission's deployment of components of the ESN project as of August 2012 resulted in unnecessary risk that sensitive information could be disclosed, modified, or obtained without authorization. This occurred, in part, because FCC did not fully implement key information security activities during the development and deployment of the initial components of the project. While FCC policy is to integrate security risk management into system life-cycle management activities, the commission instead deployed the initial components of the ESN project without, among other things, first selecting and documenting the security controls, assessing the controls, or authorizing the system to operate. As a result of these deficiencies, FCC's information remained at unnecessary risk of inadvertent or deliberate misuse, improper disclosure, or destruction. Further, addressing these deficiencies could require costly and timeconsuming rework.
FCC's efforts to effectively manage the ESN project were hindered by its inconsistent implementation of procedures for estimating costs, developing and maintaining an integrated schedule, managing project risks, and conducting oversight. If not addressed, these weaknesses could pose challenges for the commission to achieve the project's goal of improved security. Specifically, FCC
- had not developed a reliable life cycle cost estimate for ESN that includes all implementation costs;
- did not, in its project schedule, adequately identify the sequence in which activities must occur, ensure that detailed activities were traceable to higherlevel activities, or establish a baseline schedule;
- documented and managed some risks to project success, but its prime contractor did not identify any project risks until after the deployment of the initial components of the ESN project had begun; and
- had not included the ESN project in its processes for conducting regular oversight of information technology projects.
