A Murky Eight Years

The myths of HSPD-12 compliance

It has been eight years since President George W. Bush signed Homeland Security Presidential Directive 12 (HSPD-12) into law and four years since its compliance deadline. Since that time much has happened, yet one constant has remained: a lack of clarity on what true compliance with this directive requires.

HSPD-12 was issued as a call to improve physical and logical access control systems through the application of government-wide standards. Rather than employing proprietary architecture that would limit access control to an individual facility and its infrastructure, HSPD-12 called for access control interoperability among all government-run facilities, along with improved security, scalability, validity and efficiency for the system on an enterprise-wide basis.

The backbone is the personal identity verification card as outlined by Federal Information Processing Standard 201 (FIPS-201). The playbook that outlines how physical access control manufacturers can comply with HSPD-12 is found in the National Institute of Standards and Technology’s Special Publication 800-116. This is a must-read for any vendor or end user involved in complying with HSPD-12. Additionally, in early 2011, the Office of Management and Budget issued Memorandum 11-11, which created further guidelines and deadlines for agencies to reach compliance.

Compliance Myths

Eight years into the process, there is still confusion about what a federal agency needs to do to be compliant with HSPD-12. The truth is, there are many myths surrounding compliance. It behooves manufacturers, integrators and those using a physical access control system to educate themselves on what needs to be done to comply with the government-issued mandate.

One basic step toward compliance with HSPD-12 is to use a PIV card to unlock a door in a federal facility. However, in order to do that, the PIV card must be registered into the PACS that controls who can go where and when. There are several steps that should be taken prior to registering a PIV card into a PACS. First, you need to ensure that the PIV card is an authentic PIV card—not a clone or forgery. Second, you need to know that the person presenting the PIV card is truly the card owner by performing a biometric comparison. Third, check that the PIV card has not been revoked by the agency that issued it. Once these criteria have been met, registration may commence.

Thus consider Myth No. 1: It is acceptable to read the PIV card Federal Agency Smartcard Number (FASC-N) on a proximity reader and copy and paste the number into the card number field in a PACS card holder record.

This may be a “means to an end”; however, doing so gives no way of knowing if the card is authentic, whether the card actually belongs to the card holder or if the card was revoked by the agency that issued it. If any of these issues are faced, should the card be registered? Of course not!

PIV and PIV-I credentials are nothing more than expensive proximity cards if the PACS has no way to verify their authenticity, revocation status and that the person presenting the credential is the one to whom the credential was issued.

Myth No. 2: If the PIV card has been proven authentic and the cardholder is truly the card owner, there’s no need to re-check the certificate revocation list.

The certificate is defined in FIPS-201 as a data object containing a subject identifier, a public key and other information, which is digitally signed by a certification authority. Certificates convey trust in the relationship of the subject identifier and the public key. The public key is used to verify the authenticity of the credential. If the public key is not signed by a trusted issuer, then it can’t be trusted; thus, the credential cannot be trusted.

One of the biggest objections for validating a certificate is that the process more than likely requires accessing the Internet. Some end users see this as a potential security risk. But in truth, the information can’t be obtained without connectivity, so an Internet connection is just part of the compliance model. Certificate checks are important because they not only assist with validating the card but also indicate whether the card has been revoked and, if so, can initiate the proper action so the card can’t be used again. Revocations can occur at any time, so Internet access must be available at all times.

Myth No. 3: If a PACS end user purchases just one item from the GSA’s FIPS 201 Approved Products List, his or her facility automatically becomes HSPD-12 compliant. There are more than 600 products on the GSA’s FIPS-201 APL— ranging from fingerprint-capture devices and card readers to card sleeves and authentication systems. Every item used in the HSPD-12 compliance program must come from the APL, assuming there is a category for it.

But the purpose of the APL is to ensure interoperability, not necessarily compliance with a policy. If an end user purchased only one card reader that was listed on the APL but was not authenticating cards prior to PACS registration or revalidating the card’s certificates on a regular basis afterward, would that system be considered compliant? Probably not.

Myth No. 4: Visitors to federal facilities don’t have to meet the same authentication standards as the agency’s PIV card holders.

When federal employees or contractors from one agency visit another agency’s facility, they often use their PIV or PIV-I card as a flash pass. They show it to the person manning the visitors’ station but do not go through any electronic identity verification or card authentication process. Office of Management and Budget issued Memorandum 11-11 clearly states, “Agency processes must accept and electronically verify PIV credentials issued by other federal agencies.” This means that using a visitor’s PIV card as a flash pass is no longer acceptable.

Visitors’ PIV cards need to be electronically verified to ensure they are authentic, the person presenting the PIV card is the card owner by performing a biometric match and the card was not revoked by the agency that issued it. It’s unlikely that someone with a forged card would be allowed into such a facility.

Myth No. 5: Non-compliance doesn’t have any drawbacks. Nothing will happen if OMB M-11-11 is ignored because there are no funds to implement it.

OMB M-11-11 states that, effective for fiscal year 2012, “existing physical and logical access control systems must be upgraded to use PIV credentials, in accordance with NIST guidelines, prior to the agency using development and technology refresh funds to complete other activities.” Basically, that means that non-compliance can limit access to funds needed for other technology-oriented projects.

These were only five myths regarding HSPD-12 compliance, but there are many, many more. Being armed with the right tools—in this case, some necessary government documents and an understanding of what they entail—can go a long way toward ensuring compliance with HSPD-12 and preventing the headaches and expense of having to replace non-compliant equipment or make unbudgeted purchases of other tools just to meet the standard.

This article originally appeared in the October 2012 issue of Security Today.

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