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Audit of Cybersecurity Awareness Training Compliance Across Multiple State Agencies - Group Insurance Commission

November 8, 2024 · Group Insurance Commission · Read the full official report on mass.gov ↗

Published November 8, 2024 Audit covers July 1, 2021 – April 30, 2023 Under Diana DiZoglio · 2023–present

In plain English
The audit found that many Massachusetts agencies, colleges, universities, and regional transit authorities did not make sure all employees completed required cybersecurity awareness training.
source
“The purpose of our audit was to determine whether EOTSS and the above executive branch agencies, state colleges and universities, and regional transit authorities ensured that their employees completed cybersecurity awareness training in accordance with Sections 6.2.3 and 6.2.4 of EOTSS’s Information Security Risk Management Standard IS.010.”
Read the plain-English breakdown
What is this?

This is a state performance audit reviewing whether certain public agencies followed cybersecurity training rules from July 1, 2021 through April 30, 2023.

“This audit covers the period July 1, 2021 through April 30, 2023 and includes the following agencies:”
Why was it audited?

The Auditor’s Office reviewed this because Massachusetts law allows it to audit multiple public entities as part of one broader audit.

“Each entity may be audited separately as a part of a larger organizational entity or as a part of an audit covering multiple entities.”
Why it matters

If employees are not trained, agencies may be more vulnerable to cyberattacks and losses of money or public trust.

“If executive branch agencies do not ensure that all of their employees complete cybersecurity awareness training, then they may expose themselves to an increased risk of cybersecurity attacks and financial and/or reputational losses.”
What's in it for me?

For ordinary residents, this matters because EOTSS supports digital services used by taxpayers, motorists, businesses, visitors, families, and other citizens.

“EOTSS provides responsive digital and security services that enable taxpayers, motorists, businesses, visitors, families, and other citizens to do business with the Commonwealth.”
The bottom line

The audit’s answer was no: the reviewed entities did not consistently ensure employees completed cybersecurity training.

“No; see Findings 1, 2, 3, and 4”
What happens next

The Auditor’s Office said it will check back in about six months on EOTSS’s response to the findings.

“We will follow up on this during our post-audit review process in approximately six months.”
Why it's significant

The report treats this training as a basic safeguard across state government, because cyber rules help protect people, agencies, and public data.

“Cybersecurity awareness policies are not just guidelines; they are essential safeguards in today’s digital landscape.”
Jargon, unpacked

Cybersecurity awareness training means teaching employees their role in protecting state information from being exposed, unavailable, or damaged.

“The objective of the Commonwealth information security training is to educate users on their responsibility to help protect the confidentiality, availability and integrity of the Commonwealth’s information assets.”

What the Auditor checked

What the Auditor found

EOTSS did not ensure that all employees completed required cybersecurity awareness training.
cybersecurityinternal controlsrecordkeeping/documentation

Why it matters: EOTSS may expose itself to an increased risk of cybersecurity attacks and financial and/or reputational losses.

Standard: Sections 6.2.3 and 6.2.4 of EOTSS’s Information Security Risk Management Standard IS.010 require new hire and annual cybersecurity awareness training. ( EOTSS’s Information Security Risk Management Standard IS.010, Section 6.2.3; EOTSS’s Information Security Risk Management Standard IS.010, Section 6.2.4 )

4 recommendations
  • EOTSS should strengthen their policy to improve oversight of executive branch state agencies, including their timely completion of cybersecurity awareness trainings.
  • EOTSS should ensure that all employee training transcripts for all employees are maintained and include records regarding cybersecurity awareness training completion.
  • EOTSS should ensure that all of its employees complete cybersecurity awareness training within 30 days of orientation and annually thereafter.
  • EOTSS should establish procedures to monitor employee cybersecurity awareness training completion rates throughout the training cycle and use historical data retained by HRD to ensure that employees meet training deadlines.
Agency response & Auditor reply
Agency: "Moving forward, EOTSS will evaluate its internal processes to identify areas for improvement related to new hire orientation and contractor onboarding."
Auditor: "Based on its response, EOTSS has indicated that it will take steps to address our concerns on this matter."
Nine executive branch agencies did not ensure all employees completed cybersecurity awareness training.
cybersecurityinternal controlsrecordkeeping/documentation

Why it matters: The agencies may expose themselves to an increased risk of cybersecurity attacks and financial and/or reputational losses.

Standard: Sections 6.2.3 and 6.2.4 of EOTSS’s Information Security Risk Management Standard IS.010 require new hire and annual cybersecurity awareness training. ( EOTSS’s Information Security Risk Management Standard IS.010, Section 6.2.3; EOTSS’s Information Security Risk Management Standard IS.010, Section 6.2.4 )

3 recommendations
  • Provide cybersecurity awareness training, both an initial training within 30 days of orientation and an annual refresher training thereafter, to all full-time employees, contractors, and interns.agency: partially agreed
  • Establish procedures to monitor employee cybersecurity awareness training completion rates throughout the training cycle and use historical data retained by HRD to ensure employees meet training deadlines.agency: partially agreed
  • Implement additional controls to ensure that the new hire onboarding process includes all required coursework regarding cybersecurity awareness training.agency: partially agreed
Agency response & Auditor reply
Auditor: "Based on its response, DLS will take measures to address our concerns regarding this matter."
Seven state colleges and universities did not ensure all employees completed cybersecurity awareness training.
cybersecurityinternal controlsrecordkeeping/documentation

Why it matters: State colleges and universities may expose themselves to an increased risk of cybersecurity attacks and financial and/or reputational losses.

Standard: Sections 6.2.3 and 6.2.4 of EOTSS’s Information Security Risk Management Standard IS.010 require new hire and annual cybersecurity awareness training. ( EOTSS’s Information Security Risk Management Standard IS.010, Section 6.2.3; EOTSS’s Information Security Risk Management Standard IS.010, Section 6.2.4 )

2 recommendations
  • The seven state colleges and universities should update their cybersecurity awareness training policies to require this training for all employees.agency: agreed
  • The seven state colleges and universities should update their cybersecurity awareness training policies to include consequences for non-completion.agency: agreed
Agency response & Auditor reply
Agency: "We are in agreement with the merits of the [EOTSS] Standard and the University is now aligned with the goals of the cybersecurity awareness training."
Auditor: "As noted above within the auditees’ responses, many colleges and universities have already started addressing our concerns in this area."
Three regional transit authorities did not ensure all employees completed cybersecurity awareness training.
cybersecurityinternal controlsrecordkeeping/documentation

Why it matters: Regional transit authorities may expose themselves to an increased risk of cybersecurity attacks and financial and/or reputational losses.

Standard: Sections 6.2.3 and 6.2.4 of EOTSS’s Information Security Risk Management Standard IS.010 require new hire and annual cybersecurity awareness training. ( EOTSS’s Information Security Risk Management Standard IS.010, Section 6.2.3; EOTSS’s Information Security Risk Management Standard IS.010, Section 6.2.4 )

2 recommendations
  • The three regional transit authorities should update their cybersecurity awareness training policies to require this training for all employees.agency: partially agreed
  • The three regional transit authorities should update their cybersecurity training policies to include consequences for non-completion.agency: partially agreed
Agency response & Auditor reply
Agency: "The Cape Ann Transportation Authority agrees with the recommendations."
Auditor: "As noted above within the auditees’ responses, many RTAs have already started addressing our concerns in this area."