The OIG evaluated the U.S. Department of Housing and Urban Development’s (HUD) progress in applying zero trust security principles to protect personally identifiable information (PII). HUD maintained a significant number of records that contain PII with limited zero trust controls in place to secure these data. In FY 2022, HUD established a zero trust implementation plan to help the agency address the five zero trust pillars established by CISA; however, by FY 2024, HUD had made limited progress in the initiatives established in its plan. In FY 2024, HUD began to implement some technical controls to support identity pillar functions but lacked overall direction and a clear plan to make significant zero trust progress. HUD did not have an automated process to inventory or categorize data, which restricted its visibility into its PII. HUD monitored its information technology (IT) and cybersecurity risks through its OCIO risk register process; However, the register did not contain specific ZTA implementation risks. HUD did not ensure that systems applied granular access controls, including access tailored to individual actions and individual resource needs. Lastly, agencies were required to fully implement multifactor authentication (MFA) by November 2021 and phishing-resistant MFA for external users by January 2023. As of May 2024, HUD had begun phishing-resistant MFA implementation for just one of its authentication systems. We issued six recommendations to improve HUD’s management of PII in a zero trust environment.
Recommendations
Chief Information Officer
-
Status2023-OE-0007-01OpenClosed
HUD OCIO should identify needs to address Federal requirements by performing a gap analysis on its zero trust architecture strategic plan.
-
Status2023-OE-0007-02OpenClosed
HUD OCIO should establish a zero trust architecture implementation plan that includes milestones and resources to address all zero trust pillars.
-
Status2023-OE-0007-04OpenClosed
HUD OCIO should develop system policies and procedures for dynamic access controls that include just-in-time and just-enough access tailored to individual actions and individual resource needs.
-
Status2023-OE-0007-06OpenClosed
HUD OCIO should capture risks that are associated with zero trust architecture implementation and document these risks in its risk register.
Policy Development & Research
-
Status2023-OE-0007-03OpenClosed
The CDO should coordinate with HUD’s Records Office, Privacy Office, and program offices to develop data policies and procedures for data inventory, categorization, and labeling in support of zero trust architecture.
Office of Administration
-
Status2023-OE-0007-05OpenClosed
HUD’s Privacy Office should require program offices to periodically review systems in all environments (testing, development, production) for unnecessary disclosure of personally identifiable information (PII).
Housing
-
Status2023-OE-0007a-01OpenClosed
Housing should include zero trust requirements as part of the Housing Strategic Roadmap for Housing Modernization.
-
Status2023-OE-0007a-02OpenClosed
Housing should refine access controls within the FHA Catalyst modules that are dynamic, are tailored to user actions, and require continuous reauthentication to ensure that users have access only to information needed.
-
Status2023-OE-0007a-03OpenClosed
Housing should coordinate with HUD’s SOC to a. Ensure that FHA Catalyst user behavior monitoring logs are regularly captured and adequately reviewed for discrepancies in user activities. b. Establish program office responsibility for the log review process.