DOJ Helps Organizations Build Vulnerability Disclosure Programs

The U.S. Department of Justice (DOJ) Criminal Division’s Cybersecurity Unit has created a framework designed to help organizations develop formal vulnerability disclosure programs.

An increasing number of organizations have come to realize that bug bounty programs can be highly efficient for finding security holes in their networks and applications. Most of the major companies in the private sector have been running such initiatives for years and the U.S. government has also taken some important steps in this direction.

The Department of Defense has run, via the HackerOne platform, three bug bounty programs: Hack the Pentagon, Hack the Army, and Hack the Air Force.

The General Services Administration (GSA) also announced in May the launch of a bug bounty program, and senators have proposed a new bill to establish a bug bounty pilot program within the Department of Homeland Security (DHS).

The framework created by the DOJ can help both public and private sector organizations design a vulnerability disclosure program. The framework does not dictate the form or objectives of the program, and instead focuses on describing authorized discovery and disclosure conduct in an effort to reduce the chances of civil or criminal violation of the controversial Computer Fraud and Abuse Act (CFAA).

The first step, according to the DOJ’s framework, is to design the program. This includes deciding which network components and data to include in the program, deciding what types of vulnerabilities and security practices to include or exclude, and determining if third-party components or data should be included and if additional authorization needs to be obtained for them.

The DOJ also advises organizations to consult the 18F vulnerability disclosure playbook, the NTIA’s work on vulnerabilities and their disclosure, and International Standards Organization (ISO) guidance on this topic during the design phase.

The second step recommended by the framework is related to managing the program. Specifically, this includes determining how vulnerabilities are reported, assigning a point-of-contact for receiving vulnerability reports, identifying personnel who can answer questions about the program, and determining how accidental and intentional violations of the disclosure policy will be handled.

The third step involves drafting a policy that describes the organization’s intent in an accurate and unambiguous manner. This includes describing authorized and unauthorized conduct, the systems and data covered by the program, specify data access restrictions, explain the consequences for not complying with the policy, encourage researchers to contact the organization for clarifications on issues not addressed by the policy, and the necessity for including a coordination center (e.g. US-CERT, ICS-CERT) in the disclosure process.

For the final stage, the implementation of the program, the DOJ’s framework recommends making the disclosure policy easily accessible and widely available, and encouraging people who look for flaws in their systems to disclose any weaknesses via the program.