36C25819R0003-012.pdf

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Phoenix VA Health Care System Phoenix, Arizona Policy Memorandum No. HRMS/05-54 June 2013

DEPARTMENT OF VETERANS AFFAIRS NATIONAL RULES OF BEHAVIOR

I understand, accept, and agree to the following terms and conditions that apply to my access to, and use of, information, including VA sensitive information, or information systems of the U.S. Department of Veterans Affairs.

1. GENERAL RULES OF BEHAVIOR

a. I understand that an essential aspect of my job is to take personal responsibility for the secure use of VA systems and the VA data that it contains or that may be accessed through it, as well as the security and protection of VA information in any form (e.g., digital, paper).

b. I understand that when I use any government information system, I have NO expectation of privacy in any records that I create or in my activities while accessing or using such information system.

c. I understand that authorized VA personnel may review my conduct or actions concerning VA information and information systems, and take appropriate action. Authorized VA personnel include my supervisory chain of command as well as VA system administrators and ISOs. Appropriate action may include monitoring, recording, copying, inspecting, restricting access, blocking, tracking, and disclosing information to authorized OIG, VA, and law enforcement personnel.

d. I understand that the following actions are prohibited: unauthorized access, unauthorized uploading, unauthorized downloading, unauthorized changing, unauthorized circumventing, or unauthorized deleting of information on VA systems, modifying VA systems, unauthorized denying or granting access to VA systems, using VA resources for unauthorized use on VA systems, or otherwise misusing VA systems or resources. I also understand that attempting to engage in any of these unauthorized actions is also prohibited.

e. I understand that such unauthorized attempts or acts may result in disciplinary or other adverse action, as well as criminal or civil penalties. Depending on the severity of the violation, disciplinary or adverse action consequences may include: suspension of access privileges, reprimand, suspension from work, demotion, or removal. Theft, conversion, or unauthorized disposal or destruction of Federal property or information may also result in criminal sanctions.

f. I understand that I have a responsibility to report suspected or identified information security incidents (security and privacy) to my VA supervisor, ISO and PO, immediately upon suspicion.

g. I understand that I have a duty to report information about actual or possible criminal violations involving VA programs, operations, facilities, contracts or information systems to my VA supervisor, local CIO and ISO, any management official or directly to the OIG, including reporting to the OIG Hotline. I also understand that I have a duty to immediately report to the OIG any possible criminal matters involving felonies, including crimes involving information systems.

Phoenix VA Health Care System Phoenix, Arizona Policy Memorandum No. HRMS/05-54 June 2013

h. I understand that the VA National ROB do not and should not be relied upon to create any other right or benefit, substantive or procedural, enforceable by law, by a party to litigation with the U.S. Government.

i. I understand that the VA National ROB do not supersede any policies of VA facilities and other agency components that provide higher levels of protection to VA's information or information systems. The VA National ROB provide the minimal rules with which individual users must comply.

j. I understand that if I refuse to sign this VA National ROB as required by VA policy, I will be denied access to VA information systems or VA sensitive information. Any refusal to sign the VA National ROB may have an adverse impact on my employment with the Department.

2. SPECIFIC RULES OF BEHAVIOR

a. Basic

(1) I will follow established VA information security and privacy policies and procedures.

(2) I will comply with any directions from my supervisors, VA system administrators, and ISOs concerning my access to, and use of, VA information and information systems or matters covered by these ROB.

(3) I understand that I may need to sign a non-VA entity's ROB to obtain access to their system in order to conduct VA business. While using their system, I must comply with their ROB. However, I must also comply with VA's National ROB whenever I am accessing VA information systems or VA sensitive information.

(4) I may be required to acknowledge or sign additional specific or unique ROB in order to access or use specific VA systems. I understand that those specific ROB may include, but are not limited to, restrictions or prohibitions on limited personal use, special requirements for access or use of the data in that system, special requirements for the devices used to access that specific system, or special restrictions on interconnections between that system and other IT resources or systems.

b. Data Protection

(1) I will safeguard electronic VA sensitive information at work and remotely. I understand that all VA owned mobile devices must be encrypted using FIPS 140-2, Security Requirements for Cryptographic Modules, validated encryption (or its successor) unless encryption is not technically possible, as determined and approved by my local ISO, CIO and the DAS for OIS. This includes laptops, thumb drives, and other removable storage devices and storage media (e.g., CDs, Digital Video Discs (DVD)).

Phoenix VA Health Care System Phoenix, Arizona Policy Memorandum No. HRMS/05-54 June 2013

(2) I understand that per VA Directive 6609, Mailing of Sensitive Personal Information, the following types of information are excluded from the encryption requirement when mailed according to the requirements outlined in the directive:

(a) Information containing the SPI of a single individual to:

1. That person (e.g., the Veteran's, beneficiary's, dependent's, or employee's own information) or to that person's legal representative (e.g., guardian, attorney-in-fact, attorney, or Veteran Service Organization). Such information may be mailed to an entity, not otherwise the subject of an exception, with the express written consent of the individual. Such information may be mailed via U.S. Postal Service regular mail unless tracked delivery service is requested and paid for by the recipient;

2. A business partner such as a health plan or insurance company, after reviewing potential risk;

3. A court, adjudicative body, parties in litigation, or to persons or entities in the course of a judicial or administrative proceeding; and

4. Congress, law enforcement agencies, and other governmental entities.

(b) Information containing SPI of one or more individuals to a person or entity that does not have the capability to decrypt information that is encrypted by VA, when sent according to VA Directive 6609.

(3) I understand that I must have approval from my supervisor to use, process, store, or transmit electronic VA sensitive information remotely (outside of VA owned or managed facilities (e.g., medical centers, community based outpatient clinics (CBOC), regional offices)).

(4) If approved to use, process, store, or transmit electronic VA sensitive information remotely, I must ensure any device I utilize is encrypted using FIPS 140-2 (or its successor) validated encryption. Information systems must use VA's approved configuration and security control requirements. The local CIO and ISO must review and approve (in writing) the mechanisms used to transport and store the VA sensitive data before it can be removed from the VA facility.

(5) I will ensure that all printouts of VA sensitive information that I work with, as part of my official duties, are physically secured when not in use (e.g., locked cabinet, locked door).

(6) I acknowledge that particular care should be taken to protect SPI aggregated in lists, databases, or logbooks, and will include only the minimum necessary SPI to perform a legitimate business function.

(7) I recognize that access to certain databases, regional-, or national-level data such as data warehouses or registries containing patient or benefit information, and data from other Federal agencies such as the Centers for Medicare and Medicaid or the Social Security Administration, has the potential to cause great risk to VA, its customers and employees due to the number Phoenix VA Health Care System Phoenix, Arizona Policy Memorandum No. HRMS/05-54 June 2013 and/or sensitivity of the records being accessed. I will act accordingly to ensure the confidentiality and security of these data commensurate with this increased potential risk.

(8) If I have been approved by my supervisor to take printouts of VA sensitive information home or to another remote location outside of a VA facility, or if I have been provided the ability to print VA sensitive information from a remote location to a location outside of a VA facility, I must ensure that the printouts are destroyed to meet VA disposal requirements when they are no longer needed and in accordance with all relevant records retention requirements. Two secure options that can be used are to utilize a shredder that meets VA and NIST's requirements or return the printouts to a VA facility for appropriate destruction.

(9) When in an uncontrolled environment (e.g., public access work area, airport, or hotel), I will protect against disclosure of VA sensitive information which could occur by eavesdropping, overhearing, or overlooking (shoulder surfing) from unauthorized persons. I will also follow a clear desk policy that requires me to remove VA sensitive information from view when not in use (e.g., on desks, printers, fax machines, etc.). I will also secure mobile and portable computing devices (e.g., laptops, USB thumb drives, PDA).

(10) I will use VA approved encryption to encrypt any e-mail, including attachments to the e-mail that contains VA sensitive information before sending the e-mail. I will not send any e-mail that contains VA sensitive information in an unencrypted form. I will not encrypt e-mail that does not include VA sensitive information or any e-mail excluded from the encryption requirement under para. b(2).

(11) I will not auto-forward e-mail messages to addresses outside the VA network.

(12) I will take reasonable steps to ensure fax transmissions are sent to the appropriate destination, including double checking the fax number, confirming delivery of the fax, using a fax cover sheet with the required notification message included and only transmitting individually identifiable-information via fax when no other reasonable means exist and when someone is at the machine to receive the transmission or the receiving machine is in a secured location.

(13) I will protect VA sensitive information from unauthorized disclosure, use, modification, or destruction, including using encryption products approved and provided by VA to protect sensitive data. I will only provide access to sensitive information to those who have a need-to-know for their professional duties, including only posting sensitive information to web-based collaboration tools restricted to those who have a need-to-know and when proper safeguards are in place for sensitive information. For questions regarding need-to-know and safeguards, I will obtain guidance from my VA supervisor, local CIO, and/or ISO before providing any access.

(14) When using wireless connections for VA business I will only use VA authorized wireless connections and will not transmit VA sensitive information via wireless technologies unless the connection uses FIPS 140-2 (or its successor) validated encryption.

(15) I will properly dispose of VA sensitive information, either in hardcopy, soft copy, or electronic format, in accordance with VA policy and procedures.

Phoenix VA Health Care System Phoenix, Arizona Policy Memorandum No. HRMS/05-54 June 2013

(16) I will never swap or surrender VA hard drives or other storage devices to anyone other than an authorized OIT employee.

c. Logical Access Controls

(1) I will follow established procedures for requesting access to any VA computer system and for notification to the VA supervisor, local CIO, and/or ISO when the access is no longer needed.

(2) I will only utilize passwords that meet the VA minimum requirements defined in control IA-5: Authenticator Management in VA Handbook 6500, Appendix F, including using compliant passwords for authorized web-based collaboration tools that may not enforce such requirements.

(3) I will protect my verify codes and passwords from unauthorized use and disclosure. I will not divulge a personal username, password, access code, verify code, or other access requirement to anyone.

(4) I will not store my passwords or verify codes in any file on any IT system, unless that file has been encrypted using FIPS 140-2 (or its successor) validated encryption and I am the only person who can decrypt the file. I will not hardcode credentials into scripts or programs.

(5) I will use elevated privileges (e.g., Administrator accounts), if provided for the performance of my official duties, only when such privileges are needed to carry out specifically assigned tasks which require elevated access. When performing general user responsibilities, I will use my individual user account.

d. Remote Access/Teleworking

(1) I understand that remote access is allowed from other Federal Government computers and systems to VA information systems, subject to the terms of VA and the host Federal agency's policies.

(2) I agree that I will directly connect to the VA network whenever possible. If a direct connection to the VA network is not possible, then I will use VA-approved remote access software and services. I will use VA-provided IT equipment for remote access when possible.

(3) I agree that I will not have both a VA network connection and any non-VA network connection (including a modem or phone line or wireless network card, etc.) physically connected to any computer at the same time unless the dual connection is explicitly authorized in writing by my VA supervisor, local CIO, and ISO.

Phoenix VA Health Care System Phoenix, Arizona Policy Memorandum No. HRMS/05-54 June 2013

(4) I am responsible for the security of VA property and information, regardless of my work location. VA security policies are the same and will be enforced at the same rigorous level when I telework as when I am in the office. I will keep government furnished equipment (GFE) and VA information safe, secure, and separated from my personal property and information.

(5) I will ensure that VA sensitive information, in any format, and devices, systems and/or software that contain such information or that I use to access VA sensitive information or information systems are adequately secured in remote locations (e.g., at home and during travel) and agree to periodic VA inspections of the devices, systems or software from which I conduct access from remote locations. I agree that if I work from a remote location, pursuant to an approved telework agreement with VA sensitive information, authorized OIT personnel may periodically inspect the remote location for compliance with required security requirements.

(6) I will protect information about remote access mechanisms from unauthorized use and disclosure.

(7) I will notify my VA supervisor, local CIO and ISO prior to any international travel with a mobile device (laptop, PDA) so that appropriate actions can be taken prior to my departure and upon my return, including potentially issuing a specifically configured device for international travel and/or inspecting the device or re-imaging the hard drive upon return.

(8) I will exercise a higher level of awareness in protecting mobile devices when traveling internationally as laws and individual rights vary by country and threats against Federal employee devices may be heightened.

e. Non-VA Owned Systems

(1) I agree that I will not allow VA sensitive information to reside on non-VA systems or devices unless specifically designated and approved in writing in advance by my VA supervisor, local CIO, and ISO. I agree that I will not access, transmit, or store remotely any VA sensitive information that is not encrypted using VA approved encryption.

(2) I will only use VA-approved solutions for connecting non-VA owned systems to VA's network.

(3) I will obtain my local CIO's approval prior to connecting any non-VA equipment to VA's network at a VA facility. This includes directly connecting to a network port or utilizing remote access capabilities within the VA facility.

f. System Security Controls

(1) I will not attempt to override, circumvent, or disable operational, technical, or management security controls unless expressly directed to do so in writing by authorized VA staff. I will not attempt to alter the security configuration of government equipment unless authorized.

Phoenix VA Health Care System Phoenix, Arizona Policy Memorandum No. HRMS/05-54 June 2013

(2) I will only use VA approved solutions for connecting non-VA owned systems to VA's network.

(3) I will obtain my local CIO's approval prior to connecting any non-VA equipment to VA's network at a VA facility. This includes directly connecting to a network port or utilizing remote access capabilities within the VA facility.

f. System Security Controls

(1) I will not attempt to override, circumvent, or disable operational, technical, or management security controls unless expressly directed to do so in writing by authorized VA staff. I will not attempt to alter the security configuration of government equipment unless authorized.

(2) I will only use virus protection software, anti-spyware, and firewall/intrusion detection software authorized by VA on VA equipment.

(3) I will not disable or degrade software programs used by VA that install security software updates to VA computer equipment, to computer equipment used to connect to VA information systems, or to create, store or use VA information.

(4) I agree to have issued GFE scanned and serviced by VA authorized personnel. This may require me to return it promptly to a VA facility upon demand.

(5) I will permit only those authorized by OIT to perform maintenance on IT components, including installation or removal of hardware or software.

g. System Access

(1) I will use only VA approved devices, systems, software, services, and data which I am authorized to use, including complying with any software licensing or copyright restrictions.

(2) I will only use VA approved collaboration technologies for conducting VA business.

(3) I will not download software from the Internet, or other public available sources, offered as free trials, shareware, or other unlicensed software to a VA owned system.

(4) I will not host, set up, administer, or operate any type of Internet server or wireless access point on any VA network unless explicitly authorized in writing by my local CIO and approved by my ISO. I will ensure that all such activity is in compliance with Federal and VA policies.

(5) I will not attempt to probe computer systems to exploit system controls or to obtain unauthorized access to VA sensitive data.

(6) I will only use my access to VA computer systems and/or records for officially authorized and assigned duties. The use must not violate any VA policy regarding jurisdiction, restrictions, limitations or areas of responsibility.

Phoenix VA Health Care System Phoenix, Arizona Policy Memorandum No. HRMS/05-54 June 2013

(7) I will use my access under VA Directive 6001, Limited Personal Use of Government Office Equipment Including Information Technology, understanding that this Directive does not pertain to accessing VA applications or records. I will not engage in any activity that is prohibited by the Directive.

(8) I will prevent unauthorized access by another user by ensuring that I log off or lock any VA computer or console before walking away or initiate a comparable application feature that will keep others from accessing the information and resources available in my computing session.

h. Miscellaneous

(1) I will complete mandatory periodic security and privacy awareness training within designated timeframes, and complete any additional role-based security training required, based on my roles and responsibilities.

(2) I will take precautions as directed by communications from my ISO and local OIT staff to protect my computer from emerging threats.

(3) I understand that while logged into authorized Web-based collaboration tools I am a representative of VA and I will abide by the ROB and all other policies and procedures related to these tools.

(4) I will protect government property from theft, loss, destruction, or misuse. I will follow VA policies and procedures for handling Federal Government IT equipment and will sign for items provided to me for my exclusive use and return them when no longer required for VA activities.

3. ACKNOWLEDGEMENT AND ACCEPTANCE

a. I acknowledge that I have received a copy of these Rules of Behavior.

b. I understand, accept and agree to comply with all terms and conditions of these Rules of Behavior.

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