ASSET MANAGEMENT POLICY
City of Helena/Lewis and Clark County IT&S
    Information Security Policy Manual
 Asset Management Policy
Version Control
                       ITSEC004                           IT&S Steering Committee
   Policy Code:                          Approved By:            3/24/2021
                                                             IT Board 4/8/2021
         Owner:            IT&S         Effective Date:           4/8/2021
Revision History
 Date        Version       Created by    Description of change
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Asset Management Policy
Table of Contents
1.      PURPOSE AND SCOPE .....................................................................................................4
2.     ROLES AND RESPONSIBILITIES .........................................................................................4
     2.1 OWNERSHIP OF ASSETS ............................................................................................................. 5
3.     DATA CLASSIFICATION ....................................................................................................6
     3.1  INITIAL ASSET CLASSIFICATION AND REVIEW ............................................................................. 7
4.      LABELING OF INFORMATION ASSETS ...............................................................................7
5.      HANDLING OF INFORMATION ASSETS .............................................................................8
6.      SYSTEMS CLASSIFICATION .............................................................................................11
7.     DEVICE AND MEDIA CONTROLS .....................................................................................11
     7.1   ACQUISITION ..................................................................................................................... 11
     7.2   INVENTORY & ACCOUNTABILITY ........................................................................................... 12
     7.3   SOFTWARE APPLICATION ..................................................................................................... 12
     7.4   MANAGEMENT OF REMOVABLE MEDIA ................................................................................. 13
     7.5   MAINTENANCE AND PATCH MANAGEMENT............................................................................ 13
     7.6   DESTRUCTION AND DISPOSAL ............................................................................................... 13
     7.7   MEDIA RE-USE .................................................................................................................. 14
     7.8   RETURN OF ASSETS............................................................................................................. 14
8.      POLICY MAINTENANCE AND MANAGEMENT .................................................................14
9.      REFERENCES .................................................................................................................15
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Asset Management Policy
1. Purpose and Scope
The purpose of this document is to provide guidelines for the management and accountability of
information and technology assets. The purpose of this policy is to establish the proper criteria
and procedures surrounding the acquisition, inventory, and maintenance of organizational assets,
thus ensuring their secure and adequate management. City of Helena/Lewis and Clark County
IT&S (IT&S) is committed to maintaining a detailed inventory of all IT assets, such as servers,
computers, networking equipment, and storage devices.
2. Roles and Responsibilities
                                Roles and Responsibilities
                                                   •   Overseeing the management of IT
                                                       Assets.
                                                   •   Serving as a resource for information
                                                       Owners and Users on the use of
                                                       technical controls for the proper
                                                       handling and protection of data.
                                                   •   Approving IT purchases.
                  IT Director                      •   Approving the IT asset disposal list
                                                       created and maintained by the
                                                       Helpdesk.
                                                   •   Ensuring compliance with the
                                                       requirements of this policy to support
                                                       the security of IT&S assets.
                                                   •   Other responsibilities that relate to asset
                                                       management.
                                                   •   Supporting the management of all
                                                       components of the IT asset lifecycle,
                                                       including but not limited to:
                                                   •   Overseeing, or delegating, the
                                                       management of all components of the IT
                                                       asset lifecycle, including but not limited
                                                       to:
                                                         o Implementation
                                                         o Installation
                                                         o Asset Maintenance
                                                         o Asset Accountability
                                                         o Asset Disposal
              IT&S Department
                                                   •   Ensuring the inventory of IT assets is up
                                                       to date and complete.
                                                   •   Implementing technical controls to
                                                       support secure handling and protection
                                                       of data.
                                                   •   Notifying personnel such as the IT
                                                       Director, or the legal owner, of
                                                       discrepancies, disposals, or damages
                                                       involving organizational IT assets.
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Asset Management Policy
                                                    •   Reporting any loss, theft, or damage of
                                                        IT&S IT assets to IT&S.
                                                    •   Classifying information and IT assets in
                                                        accordance with the requirements of
        Asset & Information Owners                      this policy
                                                    •   Initial classification and review of
                                                        classification to ensure accuracy
                                                    •    Following the handling, labeling, and
                                                        controls identified in this policy
                                                    •   Using information assets solely as
                                                        required for business activities and in
                                                        accordance with the rules and
                                                        guidelines of IT&S policies
                                                    •   Following the labeling and secure
                Employee/Users                          handling requirements as defined in
                                                        this policy
                                                    •   Reporting any loss, theft, or damage of
                                                        IT&S IT assets to IT&S.
2.1 Ownership of Assets
The term “owner” refers to the individual(s) or business unit(s) who have the authority and
responsibility for properly classifying and managing IT and information assets.
These individuals or business units are responsible for ensuring:
    •   That IT assets are inventoried in accordance with the requirements discussed in this
        policy;
    •   That assets are appropriately classified, handled and protected in accordance with this
        policy and other policies, including but not limited to:
            o   Access Control and Authorization Policy
            o   Data Integrity and Encryption Policy
            o   Acceptable Use Policy
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Asset Management Policy
3. Data Classification
All IT&S information assets require an assigned classification level. The classification level must
consider the impact of disclosure, the degree of sensitivity, and any legal or contractual
obligations relevant to the information asset. Information assets should be analyzed to determine
their level of sensitivity and criticality in accordance with the classification model outlined below.
All information assets must be clearly and appropriately labeled with the assigned classification
level.
                                    Data Classification Model
     Classification Level                     Definition                          Examples
                                                                          •    PII data
                                                                          •    ePHI
                                                                          •    Credit card information
                                    Any information that is               •    Financial information,
                                    extremely sensitive in nature,             such as billing info.
                                    including but not limited to          •    Payroll data
                                    regulated data, sensitive client
                                                                          •    Social Security Numbers
                                    information, financial
                                    information, or proprietary           •    Administrative
                                    data. Unauthorized internal or             passwords or
         Confidential               external access to this data               administrative access
                                    could have a major impact on               information
                                    the company. Strict rules             •    Source code
                                    should be adhered to in the           •    Customer data
                                    usage of this data, including         •    Penetration test or
                                    any specific rules imposed by              vulnerability assessment
                                    the applicable laws,                       results
                                    regulations, and/or contracts.        •    Any other regulated
                                                                               data
                                                                          •    Network maps
                                    Any information that is not
                                    considered confidential but
                                    should be restricted to specific      •    User ID’s and passwords
                                    personnel or groups should be
                                                                          •    Client lists
                                    considered restricted. This
                                                                          •    Pricing schemes
                                    will include but is not limited
           Restricted                                                     •    Personnel records
                                    to network architecture,
                                    general security concerns,                 software and hardware
                                    company pricing information,               information
                                    client lists, or any other            •    File Access Rights
                                    relevant information that is
                                    not available to the public.
                                    Any information relating to           •    Company general emails
                                    internal company operations,          •    Company calendar
                                    which is not available to the         •    IT&S policies and
                                    public. External access to this            procedures
            Internal                information is to be prevented,       •    Intranet site
                                    but if it became public, the          •    Insert additional
                                    consequences are not critical              internal data as relevant
                                    and would have limited
                                    impact.
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Asset Management Policy
                                     Information available to the          •   Public Facing Web
                                     public without restriction.               Content
                                     Such information will not have        •   IT&S contact information
               Public
                                     adverse effects on the                •   Marketing Material
                                     organization if exposed to the
                                     public
3.1       Initial Asset Classification and Review
IT&S employees are responsible for recognizing the classification level of information assets and
taking appropriate actions in accordance with this policy. As applicable, employees will receive
orientation from IT&S staff to review IT&S Policies, including the information classification and
handling requirements of this policy. The IT&S Policies Acknowledgement form agreeing to
adhere to the City/County policies must be signed. All employees will be trained on the
classification, labeling, and handling requirements of this policy as part of initial and recurring
training.
Additionally, the classification levels of IT&S information assets must be reviewed periodically to
ensure classifications are still accurate and identify any needed changes. The information owner
is responsible for such review.
4. Labeling of Information Assets
All information assets must be clearly and appropriately labeled with the assigned classification
level.
      •   Public information – no labeling requirements. However, adding the label “Public” (or
          “Unrestricted”) is advisable if possible – to avoid confusion.
      •   Internal, Restricted, and Confidential information – should be labeled with the
          appropriate classification name. If a document contains data in different classification
          levels, the highest level of classification will determine the classification of the document
          and the appropriate label.
      •   Classification labels in electronic documents should appear on every page when the
          document is viewed or printed. This can be achieved by adding a header and/or footer to
          the document indicating the classification level.
      •   Classification labels on removable/portable media should be clearly visible.
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Asset Management Policy
5. Handling of Information Assets
The following table provides the requirements for handling assets and data based on the
classification level. If an asset contains data in different classification levels, the highest level of
classification will determine the classification of the asset and the appropriate handling
requirements.
                                 SECURITY CONTROLS BY CLASSIFICATION LEVEL
        Activity
                                                                Restricted /
                                  Confidential                   Internal                   Public
 Electronic                Information must be              Information must be        No
 Document                  stored on company-owned          stored on company-         requirements.
 Storage                   devices. Data must be            owned devices.             The data can be
                           encrypted using approved         Devices must be            shared.
                           encryption methods in            secured from
                           accordance with the Data         unauthorized access.
                           Integrity and Encryption
                           Policy.
                           Media must be secured in
                           a locked storage area when
                           not in use.
 Hard Copy                 Must not be left                 Must not be left           No
 (printed                  unattended in areas with         unattended in areas        requirements.
 material)                 public access. Must be           with public access.        The document
                           stored in a locked               The document must          can be shared.
                           container or cabinet, or in      be stored in a locked
                           an office area with              cabinet
                           restricted access.
                           Must be destroyed using a
                           shredder or placed in
                           central shredding bins that
                           are shredded routinely.
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Asset Management Policy
                               SECURITY CONTROLS BY CLASSIFICATION LEVEL
      Activity
                                                            Restricted /
                                Confidential                 Internal                Public
Electronic                Transfer to internal or       Must be transferred      No
Transfer                  external parties must be      internally to only       requirements
(i.e. Email, SFTP)        done based on a need-to-      authorized
                          know. Transfer to external    personnel. When
                          parties requires an NDA       files are transmitted,
                          and approval from the         they must be
                          data owner.                   securely protected
                          Minimum 128-bit               Transfer to external
                          encryption (e.g. SSL/TLS)     parties requires an
                          is required for all           NDA.
                          communications outside        Minimum 128-bit
                          of an IT&S network.           encryption (e.g.
                          Encryption (e.g. SSL/TLS)     SSL/TLS) is required
                          is required for all           for all
                          communications outside        communications
                          of an IT&S network and        outside of an IT&S
                          must meet the                 network.
                          requirements of the Data
                          Integrity and Encryption
                          Policy.
Information               Only authorized persons       The information          No
Systems                   may have access. Access       system must be           Requirements
                          must be restricted based      protected from
                          on the principal of least     external access and
                          privilege and in              password protected.
                          accordance with the           Users must use care
                          Access Control and            to prevent shoulder-
                          Authorization Policy.         surfing or other
                          Access to the information     viewing by
                          system must be protected      unauthorized users
                          by a strong password.         and must lock device
                          The system should be          screens when
                          configured to                 unattended.
                          automatically lock or
                          terminate inactive session
                          after 15 minutes of
                          inactivity.
Disposal of               In addition to removing       Files/data must be       No
Information               the file, the space used by   removed via the          Requirements
(electronic)              the file must be              system’s “delete” or
                          overwritten or formatted      “remove” function.
                          using approved means.
                          (permanent destruction)
                          Data must only be deleted
                          after the information’s
                          retention period.
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Asset Management Policy
                              SECURITY CONTROLS BY CLASSIFICATION LEVEL
      Activity
                                                          Restricted /
                                Confidential               Internal              Public
Disposal of               ALL media must be            Media must be          No
Physical Medium           disposed of securely using   disposed of securely   Requirements
(e.g.,                    approved methods (e.g.       using approved
paper/magnetic            shredding, overwriting of    methods (e.g.
media)                    magnetic media) and          shredding,
                          based on retention           overwriting of
                          strategies.                  magnetic media) and
                                                       based on retention
                          A record of media            strategies.
                          disposals must be
                          maintained by IT&S.
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Asset Management Policy
6. Systems Classification
In conjunction with risk analysis activities, a criticality analysis will be performed to determine
the criticality of IT&S systems to business operations.
IT&S will inventory all information systems, as well as identify and document dependencies
between systems. Using this information, the IT Director (and Security Officer) will classify each
system by criticality, with input from relevant departments, subject matter experts, and
management as needed. The following table outlines the varying impact of system unavailability,
or how critical the system is.
                                                                            Time in which incident
      Criticality Level                     Description
                                                                              must be addressed
                           Loss of system availability could result in a   Incident must be
            High
                           severe business impact.                         addressed immediately
                           System unavailability could result in           Incident must be
           Medium
                           significant loss of operations.                 addressed within 2 hours
                           System unavailability could result in a         Incident must be
            Low            limited impact to individual users or           addressed within 24
                           department.                                     hours
                                                                           Incident may be
                           System unavailability results in virtually no
           Minimal                                                         addressed when
                           impact to operations, users, or departments.
                                                                           convenient
The Security Officer will coordinate the documentation of the results of the system criticality
analysis in a list of critical systems, which will be used to support contingency planning and the
prioritization of recovery activities. This document will contain:
      •    The criticality level of each system
      •    The corresponding system owner
      •    Business function
      •    System dependencies
      •    Information asset(s) stored, processed, transmitted, or created on the system
7. Device and Media Controls
This section outlines the implementation, destruction and re-use of IT&S’s media devices. These
devices include but are not limited to:
    • Servers
    • Terminals
    • Workstations/laptops
    • Mobile phones/tablets
    • Portable storage media (i.e. USB drives, SD cards)
    • External hard drives
    • Networking equipment
    • Software and licenses
    • Databases
    • Output devices (i.e. scanners, photocopiers, printers, fax machines)
7.1       Acquisition
The IT Director or designated IT staff must approve all equipment purchases. Requests for the
purchase of new equipment must be sent to the IT Director or designated IT staff as a Hardware
Request Form. All monies for spending must be pre-approved via purchase order by The IT
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Director or designated IT staff. The IT Director or designated IT staff must also approve the
purchase order.
    •   Type of Asset requested
    •   Business justification
    •   Cost or estimated cost
    •   Urgency
After the Hardware Request has been approved, the IT Director or designated IT staff will make
the purchase or delegate the purchase to another employee.
7.2 Inventory & Accountability
IT&S will maintain a current and accurate inventory if its IT assets to support access to asset
information needed for patch and vulnerability management, incident response, and business
continuity.
Each asset must be assigned a unique ID. IT&S will keep a record of company information
systems (KACE). The IT Director or designated IT staff is responsible for maintaining the
inventory, which includes tracking ownership and maintenance of the systems.
Each entry should include the following, if applicable (KACE or CPU Label):
    •   Asset ID
    •   Asset classification
    •   Serial number, manufacturer, model
    •   Asset owner (indicate the Department to whom the asset has been assigned to)
    •   Date of purchase
    •   Description of business function
    •   Location
    •   IP Address
    •   Software and licensing information
    •   Value of purchase
    •   Purchase order reference number
    •   Vendor contact
    •   Licensing information
    •   Version and update information.
    •   System backup and maintenance status
    •   Service contract or maintenance contract details, if applicable
    •   Disposal and destruction status, and method of destruction
If information contained within the asset inventory becomes outdated, the IT Director or
designated IT staff must make the necessary changes in a timely manner. This will ensure that
IT&S has complete knowledge of the current information systems and related activities. The IT
Director must coordinate the review of the asset inventory at least annually, to confirm the
accuracy of the document.
7.3 Software Application
IT&S will maintain an inventory of its software applications. These software applications include,
but are not necessarily limited to, the following:
    •   Application Software (Licensed)
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    •   Freeware/Shareware
    •   System Software
    •   Various Tools
    •   Databases
This inventory of software applications will adhere to the requirements mentioned above in
Inventory and Accountability. Additionally, this inventory will include the following information:
    •   Pertinent location information of the software;
    •   Licensing information, including any specific license keys
    •   Pertinent information relating to its functionality or security (e.g., baseline software
        configurations, approved deviations, etc.)
    •   Information needed to support technical vulnerability management
7.4 Management of Removable Media
Use and management of removable media is subject to the following requirements:
    •   Use of removable media in workstations should be monitored and restricted. Users are
        only permitted to use removable media if a legitimate business need exists. Request and
        approval of removable media must adhere to the requirements outlined in the Access
        Control and Authorization Policy and Acceptable Use Policy.
    •   Only approved removable media devices may be used. Removable media (i.e. USB Drives)
        may be issued to users by the IT Department and will be tracked to ensure such media is
        returned for proper disposal and/or removal of data.
    •   Removable media must not be used in servers unless required for performing specific
        tasks and removed immediately once completed. Physical access to servers and ports
        used for removable media must be restricted to authorized personnel only.
7.5 Maintenance and Patch Management
It is essential to the security of IT&S systems and information that all technology assets have the
most recent operating system and application updates (aka “patches”) installed.
The Network Manager and Network Staff are responsible for overseeing patch management
implementation, procedures, and timing/scheduling of patches. The Network Staff and Network
Staff will be responsible for carrying out patch management procedures such as patching servers,
workstations, and infrastructure components (switches, routers, etc.). When possible, systems
will be configured to accept automatic updates. The Network Manager and Network Staff are
responsible for establishing a patch schedule for systems that do not automatically update.
The Network Manager and Network Staff will also consult various resources to stay informed
about current security threats and available patches.
The IT Director must approve any off-site maintenance of equipment containing information
classified as Internal or Confidential. The data on the device must be backed up and completely
wiped from the device prior to taking the device off-site for maintenance.
7.6 Destruction and Disposal
As organizational assets lose functionality or are no longer needed, disposal may be necessary.
IT&S will ensure that all information assets are properly destroyed and/or erased when no longer
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needed. Disposal of IT&S IT assets must be formally approved by the IT Director. Upon approval,
the IT Director or designated IT staff is responsible for the destruction and disposal of media and
devices, as well as their removal from the inventory of assets.
Prior to redistribution, salvage, or disposal, all sensitive information must be erased from the
specific IT assets. All electronic information must be overwritten bit by bit. IT Staff will confirm
through technical testing that removal procedures are successful and complete. Hardware assets
to be destroyed may also be disposed through an authorized disposal company. Certificates of
destruction must be obtained. Any hardware awaiting destruction or disposal must be stored in a
secure area.
7.7 Media Re-use
Some devices, such as hard drives and computers, may be reused after properly removing all
sensitive information. IT Staff will ensure that the requirements for removal outlined in the
section above, 5.4 Destruction and Disposal, are applied to all devices before they are made
available for reuse.
The Board of County Commission (BOCC) is also responsible for transferring ownership of a
reused device in the asset inventory. If media is not intended for recycle or reuse, the best control
may be destruction.
7.8 Return of Assets
IT&S employees and certain external party users sometimes have IT assets in their personal
possession. For example, IT&S issues laptop computers to certain employees. Upon termination
of these individuals’ relationships with IT&S these IT assets must be returned.
IT&S must see to it that these IT assets are returned as soon as possible and that IT&S follows any
other information security policies relevant to the IT asset’s return or the termination of the
relationship with the individual.
In the event the individual refuses or is unable to return the IT asset, IT&S is required to abide by
its information security policies that apply to such a scenario.
8. Policy Maintenance and Management
The Owner of this document must evaluate and perform any necessary updates to this document
at least once per year. The owner may delegate tasks related to this policy.
       The IT Director will adhere to the continual validation, review, and updating of this
        policy.
       When evaluating this policy, the number of discrepancies within the Inventory of Assets
        as well as any incidents of unauthorized access, transfer, or disposals must be considered.
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9. References
NIST Cybersecurity Framework References
   • ID.AM – Asset Management
   • PR.IP – Information Protection Processes and Procedures
   • PR.DS – Data Security
   • PR. MA – Maintenance
   • PR.PT – Protective Technology
Policy References
   • Access Control and Authorization Policy
   • Acceptable Use Policy
   • Data Integrity and Encryption Policy
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