BILL ANALYSIS                                                                                                                                                                                                    Ó



                                                                     AB 670


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          CONCURRENCE IN SENATE AMENDMENTS


          AB  
          670 (Irwin)


          As Amended  September 3, 2015


          Majority vote


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          Original Committee Reference:  P. & C.P.




          SUMMARY:  Requires the Department of Technology (Department) to  
          conduct, or require to be conducted, no fewer than 35  
          independent security assessments of state agencies, departments  
          or offices annually.  Specifically, this bill:  


          1)Authorizes the California Information Security Office (ISO)  
            within the Department to conduct, or require to be conducted,  
            an independent security assessment of every state agency,  
            department, or office. 


          2)Requires the cost of an independent security assessment to be  
            funded by the state agency, department, or office being  
            assessed.









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           3) Requires ISO, in consultation with the Office of Emergency  
             Services (OES), to perform all the following duties:


             a)   Annually require no fewer than 35 state entities to  
               perform an independent security assessment, the cost of  
               which shall be funded by the state agency, department, or  
               office being assessed. 
             b)   Determine criteria and rank state entities based on an  
               information security risk index that may include, but not  
               be limited to, consideration of the following factors:


               i)     Personally identifiable information protected by  
                 law.
               ii)    Health information protected by law.


               iii)   Confidential financial data.


               iv)    Self-certification of compliance and indicators of  
                 unreported noncompliance with security provisions related  
                 to information asset management, risk management,  
                 information security program management, information  
                 security incident management and technology recovery  
                 planning.  


             c)   Determine the basic standards of services to be  
               performed as part of an independent security assessment. 
          4)Authorizes the Military Department to perform an independent  
            security assessment of any state agency, department, or  
            office, the cost of which shall be funded by the state agency,  
            department, or office being assessed. 
          5)Requires state agencies and entities required to conduct or  
            receive an independent security assessment to transmit the  
            complete results of that assessment and recommendations for  
            mitigating system vulnerabilities, if any, to ISO and OES. 










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          6)Requires ISO to report to the Department and OES any state  
            entity found to be noncompliant with information security  
            program requirements. 


          7)Specifies, notwithstanding any other law, that during the  
            process of conducting an independent security assessment,  
            information and records concerning the assessment are  
            confidential and shall not be disclosed, except to approved  
            state employees and state contractors.  


          8)Declares the results of a completed independent security  
            assessment and any related information to be subject to all  
            disclosure and confidentiality provisions under state law,  
            including the California Public Records Act. 


          9)Requires the Department to notify OES, the California Highway  
            Patrol, and the Department of Justice regarding any criminal  
            or alleged criminal cyber activity affecting any state entity  
            or critical infrastructure of state government. 


          10)Deletes a pre-existing exemption from independent security  
            assessments for the Department of Forestry and Fire  
            Prevention.


          11)Makes findings and declaration relative to the necessity of  
            imposing a limitation on the public's right of access to the  
            meetings of public bodies or the writings of public officials  
            and agencies, namely that the state has a very strong interest  
            in protecting its information systems from intrusion, because  
            those systems contain confidential information and play a  
            critical role in the performance of the duties of state  
            government.   


          The Senate amendments generally revise and recast the provisions  
          of this bill, requiring that no fewer than 35 state entities  
          every year be required to perform an independent security  








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          assessment, setting broad criteria for the assessment, and  
          clarifying the provisions for transmission and disclosure of  
          assessment results.  


          FISCAL EFFECT:  According to the Senate Appropriations  
          Committee: 


          1)[the Department] would incur costs of approximately $2 million  
            in 2016-17, and ongoing costs of approximately $1.9 million  
            for 12 Personnel Year of staff to conduct security  
            assessments.  Staff estimates that ISO would have additional  
            costs in the hundreds of thousands annually for travel and  
            other associated charges.  (Technology Services Revolving  
            Fund)


          2)Further, ongoing, potentially significant cost pressures for  
            state entities to make necessary Information Technology  
            improvements to address vulnerabilities identified through  
            security assessments.  However, these improvements would  
            decrease the likelihood that agencies would experience a  
            future data breach, thereby avoiding related costs in future  
            years.  (General Fund and/or Special Funds)


          3)Finally, an estimated [Department] costs in the range of  
            $100,000 to $150,000 to develop and adopt standards for the  
            ISO, Military Department, or entity conducting a security  
            assessment to follow when conducting those assessments and  
            reporting results.  These costs include necessary updates to  
            the State Administrative Manual. (Technology Services  
            Revolving Fund)


          COMMENTS:  This bill is intended to increase the security of  
          California state computer networks by requiring the ISO within  
          the Department of Technology to conduct a security assessment of  
          the information technology systems of at least 35 state  
          agencies, departments and offices under its jurisdiction every  
          year.    








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          According to the author, the State Administrative Manual  
          currently requires state government entities to conduct security  
          assessments every two years, but there is no mechanism of  
          enforcement and less than one-third of state agencies,  
          departments, or offices have conducted or received an assessment  
          to date.  These preventative assessments are a vital tool in  
          combating the increasingly sophisticated cyber-attacks because  
          they reveal vulnerabilities, demonstrate the extent of potential  
          exploitation, and provide recommendations for remediation and  
          risk mitigation.


          According to the California Military Department, California's  
          size and prominence makes it vulnerable to cyber incidents that  
          disrupt business, shutdown critical infrastructure, and  
          compromise intellectual property or national security.  A  
          targeted attack on critical infrastructure and key resources  
          could cause up to $1 billion dollars of economic impact to  
          California each day until services are restored.  According to  
          the author's office, there are a total of 384 state entities  
          subject to the ISO (which excludes some constitutional offices).  
           It is not known how many attacks, whether successful or  
          unsuccessful, have been made against state agency computers over  
          the past year.


          Under current law, ISO is authorized to conduct independent  
          security assessments of any state agency, department or office,  
          but is not required to do so.  It is not known how many security  
          assessments were conducted by ISO in the past year.  According  
          to the author's office, a security assessment will generally  
          cost a public entity between $10,000 and $40,000 to complete,  
          depending on its size and sophistication.  The assessment  
          usually takes 1-2 days, with the assessed entity receiving a  
          written report on findings within 2-3 weeks.


          An August 2015 report released by the California State Auditor  
          entitled "High Risk Update - Information Security" describes a  
          litany of shortcomings in state entities' compliance with the  








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          information security requirements of the State Administrative  
          Manual, including widespread misreporting of compliance  
          self-certification.  The Auditor found that the Department  
          "failed to take sufficient action to ensure that reporting  
          entities address these deficiencies."  The report's primary  
          legislative recommendation is to mandate the performance of an  
          independent security assessment for each entity at least every  
          two years. 


          Analysis Prepared by:                                             
                          Hank Dempsey / P. & C.P. / (916) 319-2200  FN:  
          0002224