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Education Should Take Additional Steps to Help Protect K-12 Schools from Cyber Threats (GAO-22-105024)

Summary

A GAO report to congressional requesters, GAO-22-105024, dated October 2021, on protecting K-12 schools from cyber threats. It states that when the COVID-19 pandemic forced the closure of schools across the nation, many K-12 schools moved from in-person to remote education. GAO describes federal guidance, such as the National Infrastructure Protection Plan, that specifies the roles of the Cybersecurity and Infrastructure Security Agency, the Department of Education's Office of Safe and Secure Schools and the Federal Bureau of Investigation in assisting school districts. Its title states that Education should take additional steps to help protect K-12 schools from cyber threats.

Summary drafted by a model from the document's text below and checked by script against that text before publication. It is a navigation aid, not a reading of what the document proves. Where AI is used

Full text

                United States Government Accountability Office
                Report to Congressional Requesters




                CRITICAL
October 2021




                INFRASTRUCTURE
                PROTECTION

                Education Should
                Take Additional Steps
                to Help Protect K-12
                Schools from Cyber
                Threats




GAO-22-105024
                                            October 2021

                                            CRITICAL INFRASTRUCTURE PROTECTION
                                            Education Should Take Additional Steps to Help
                                            Protect K-12 Schools from Cyber Threats
Highlights of GAO-22-105024, a report to
congressional requesters




Why GAO Did This Study                      What GAO Found
When the COVID-19 pandemic                  Federal guidance, such as the National Infrastructure Protection Plan (National
forced the closure of schools across        Plan), specify the roles and responsibilities of the Department of Homeland
the nation, many K-12 schools               Security’s Cybersecurity and Infrastructure Security Agency (CISA), the
moved from in-person to remote              Department of Education’s Office of Safe and Secure Schools, and the Federal
education, increasing their                 Bureau of Investigation to assist school districts in protecting against cyber
dependence on IT and making them            threats. These agencies have provided programs, services, and support to assist
potentially more vulnerable to              kindergarten through 12th grade (K-12) schools in defending against cyber
cyberattacks. Education Facilities,         threats. Examples of such support include incident response assistance, network
including K-12 schools, is one of the       monitoring tools, and guidance for parents and students on preparing for the
nation’s critical infrastructure            cyber threats that students face online (see table).
subsectors. Several agencies have a
role in protecting the subsector.           Federal Resources for Cyberattacks on Kindergarten through Grade 12 (K-12) Schools

GAO was asked to review
cybersecurity in K-12 schools. The
objective of this report is to
determine the extent that federal
agencies have assisted schools in
protecting themselves from cyber
threats. To do so, GAO identified
laws and federal guidance that
specify the roles and responsibilities
of federal agencies to assist schools
in protecting against cyber threats.
GAO analyzed documentation of the
types of products and services
federal agencies have in place to
identify, protect, detect, respond, and     As the lead for the education subsector, the Department of Education is
recover from attacks. In addition,          responsible for (1) developing and maintaining a sector-specific plan to address
GAO interviewed federal officials           cybersecurity risks at K-12 schools, and (2) determining the need for sector-
about such products and services            specific guidance. The Education Facilities plan was developed and issued in
they offer to K-12 schools.                 2010. Since then, the cybersecurity risks facing the subsector have substantially
What GAO Recommends                         changed. Among other things, schools have increasingly reported ransomware
                                            and other cyberattacks that can cause significant disruptions to school
GAO is making two                           operations, thus highlighting the importance of securing K-12 schools’ IT
recommendations for Education to            systems. According to data from K-12 Security Information Exchange, schools
initiate a meeting with CISA to             publicly reported 62 ransomware incidents in 2019, compared to 11 ransomware
determine how to update its sector-         incidents reported in 2018. However, Education has not updated its 2010 plan
specific plan and determine whether         and has not determined whether sector-specific guidance is needed for K-12
sector-specific guidance is needed.         schools to help protect against cyber threats. Education officials stated that the
Education concurred with GAO’s two          department has not updated the sector plan and not determined the need for
recommendations and described               sector-specific guidance because CISA has not directed it to do so. However, as
actions that it would take to address       previously stated, the department is responsible for updating its sector plan and
them.                                       determining the need for guidance. As a result, K-12 schools are less likely to
View GAO-22-105024. For more information,   have the federal products, services, and support that can best help protect them
contact Nick Marinos at (202) 512-9342 or   from cyberattacks.
marinosn@gao.gov.



                                                                                        United States Government Accountability Office
Contents


Letter                                                                                   1
               Background                                                               3
               Federal Agencies Have Provided Cybersecurity Support to K-12
                 Schools but Have Not Kept Plans Up-to-Date or Determined the
                 Need for Sector-Specific Guidance                                     15
               Conclusions                                                             24
               Recommendations for Executive Action                                    25
               Agency Comments and Our Evaluation                                      25

Appendix I     Objective, Scope, and Methodology                                       29



Appendix II    Federal Products, Services, and Support                                 32



Appendix III   Comments from the Department of Education                               34



Appendix IV    GAO Contacts and Staff Acknowledgments                                  37


Tables
               Table 1: Cyber Threat Actors                                             6
               Table 2: Examples of Recent Cyberattacks at Kindergarten
                       through Grade 12 Schools                                         7
               Table 3: Federal Products, Services, and Support That Address
                       National Institute of Standards and Technology
                       Framework Functions for the Education Facilities
                       Subsector                                                       32

Figure
               Figure 1: National Institute of Standards and Technology
                        Cybersecurity Framework Functions and Categories               11




               Page i                                      GAO-22-105024 K-12 Cybersecurity
Abbreviations

CISA                       Cybersecurity and Infrastructure Security Agency
COPPA                      Children’s Online Privacy Protection Act of 1998
COVID-19                   Coronavirus Disease 2019
DHS                        Department of Homeland Security
FBI                        Federal Bureau of Investigation
FERPA                      Family Educational Rights and Privacy Act of 1974
GSA                        General Services Administration
ISAC                       Information Sharing and Analysis Center
K-12                       kindergarten through grade 12
K12 SIX                    K-12 Security Information Exchange
MS-ISAC                    Multi-State Information Sharing and Analysis
                             Center
National Plan              National Infrastructure Protection Plan
NDAA                       National Defense Authorization Act
NIST                       National Institute of Standards and Technology
OSSS                       Office of Safe and Secure Schools
PPD-21                     Presidential Policy Directive 21
PPD-41                     Presidential Policy Directive 41
SRMA                       sector risk management agencies
SSP                        sector-specific plan




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Page ii                                                 GAO-22-105024 K-12 Cybersecurity
                       Letter




441 G St. N.W.
Washington, DC 20548




                       October 13, 2021

                       Congressional Requesters

                       Many kindergarten through grade 12 (K-12) schools moved from in-
                       person to remote education when the Coronavirus Disease 2019 (COVID-
                       19) pandemic forced the closure of schools across the nation. 1 Remote
                       education has increased K-12 schools’ dependence on IT, such as
                       laptops, wireless internet access, and cameras and microphones.

                       Such reliance on IT increases the vulnerability of K-12 schools to
                       potentially serious cyberattacks. Schools across the nation have
                       increasingly reported various types of cyberattacks. The growing number
                       of cyberattacks on schools highlights the importance of securing K-12
                       schools information technology.

                       Ensuring the cybersecurity of the nation has been on our High-Risk List
                       since 1997. In 2003, we expanded this area to include the protection of
                       critical cyber infrastructure, which includes the Education Facilities
                       Subsector as well as other sectors and subsectors.2 In September 2018,
                       we issued an update that identified actions needed to address
                       cybersecurity challenges facing the nation, including the development of a
                       more comprehensive national strategy and better oversight of national
                       cybersecurity. 3 We later identified ensuring national cybersecurity as one
                       of nine high-risk areas that need especially focused executive and
                       congressional attention. 4

                       You asked us to review cybersecurity at K-12 schools. The objective of
                       this review—the first of two reviews planned in response to your

                       1K-12 includes all public, private, and charter schools from kindergarten through 12th
                       grade. In this report, we collectively refer to all these different types of schools as “K-12
                       schools.”
                       2GAO, High-Risk Series: Progress on Many High-Risk Areas, While Substantial Efforts
                       Needed on Others, GAO-17-317 (Washington, D.C.: Feb. 16, 2017). The Education
                       Facilities Subsector includes K-12 schools, higher education institutions, and business
                       and trade schools, and falls under the Government Facilities Sector. The subsector
                       includes facilities that are owned by both government and private sector entities.
                       3GAO, High-Risk Series: Urgent Actions Are Needed to Address Cybersecurity
                       Challenges Facing the Nation, GAO-18-622 (Washington, D.C.: Sept. 6, 2018).
                       4GAO, High-Risk Series: Substantial Efforts Needed to Achieve Greater Progress on
                       High-Risk Areas, GAO-19-157SP (Washington, D.C.: Mar. 6, 2019).



                       Page 1                                                      GAO-22-105024 K-12 Cybersecurity
request—is to determine the extent to which federal agencies have
assisted schools in protecting themselves from cyber threats. We plan to
initiate a second review to assess states’ use of federal assistance to
combat cyber threats at K-12 schools and what further assistance might
be needed.

To address the objective of this review, we examined relevant law and
federal guidance, such as the National Defense Authorization Act (NDAA)
for Fiscal Year 2021, the National Infrastructure Protection Plan (National
Plan), and Presidential Policy Directive 21 (PPD-21). These authorities
specify the roles and responsibilities of the Department of Homeland
Security (DHS), the Department of Education, and the Federal Bureau of
Investigation (FBI) to assist K-12 schools in protecting against cyber
threats. 5 DHS’s Cybersecurity and Infrastructure Security Agency (CISA)
and Education’s Office of Safe and Secure Schools (OSSS) are the
department-designated agencies responsible for assisting K-12 schools in
defending against cyber threats. 6

We also collected and analyzed documentation of the types of support
these agencies offer to K-12 schools, and we interviewed officials from
the agencies about the programs, services, and products they offer to
assist schools. We compared the activities these agencies undertook to
plan for and provide assistance to support schools with the roles and
responsibilities of the agencies, as defined in laws and guidance, and
identified any gaps in the agencies’ efforts to fulfill their roles and

5Department of Homeland Security, National Infrastructure Protection Plan 2013:
Partnering for Critical Infrastructure Security and Resilience (Washington, D.C.: December
2013). The National Plan lists the Department of Education as the sector-specific agency
for the Education Facilities Subsector. PPD-21 establishes requirements for sector-
specific agencies and DHS. The fiscal year 21 NDAA renamed the term “sector-specific
agency” to “sector risk management agency” (SRMA), listed responsibilities for those
agencies, and addressed the designation of critical infrastructure sectors. The William M.
(Mac) Thornberry National Defense Authorization Act for Fiscal Year 2021 (Fiscal Year
2021 NDAA), Pub. L. No. 116-283, § 9002.
6The Education Facilities Sector-Specific Plan designates the department’s Office of Safe
and Drug Free Schools as the sector risk management agency (SRMA) for the Education
Facilities Subsector. Department of Homeland Security and Department of Education,
Education Facilities Sector-Specific Plan: An Annex to the Government Facilities Sector-
Specific Plan (2010). Department of Education officials stated that this office is now known
as the Office of Safe and Supportive Schools (OSSS). In addition, the Cybersecurity and
Infrastructure Security Agency Act of 2018 created CISA, within the Department of
Homeland Security. Pub. L. No. 115–278, title XXII, 132 Stat. 4168-4186 (Jan. 3, 2018).
As such, DHS responsibilities for the protection of critical infrastructure were assigned to
CISA.




Page 2                                                   GAO-22-105024 K-12 Cybersecurity
             responsibilities. We discussed our assessment with agency officials from
             CISA, OSSS, and the FBI to determine the reasons for any apparent
             gaps in agency efforts.

             In addition, we compared planning documents, such as the Education
             Facilities and Government Facilities Sector-Specific Plans (SSPs) to
             GAO’s key characteristics of a national strategy to further identify gaps in
             the agencies’ efforts to fulfill their roles and responsibilities in supporting
             the Education subsector. 7

             We further identified significant threats facing the subsector by analyzing
             K-12 cyber incidents that were identified in a prior GAO report. 8 We
             analyzed the Education Facilities SSP to determine the extent to which it
             addressed these and other types of cyber threats facing the subsector.
             We discussed our assessment of the subsector plan with OSSS and
             CISA officials to determine the reasons for apparent gaps in agency
             planning efforts. Appendix I discusses our objectives, scope, and
             methodology in greater detail.

             We conducted this performance audit from February 2021 to October
             2021 in accordance with generally accepted government auditing
             standards. Those standards require that we plan and perform the audit to
             obtain sufficient, appropriate evidence to provide a reasonable basis for
             our findings and conclusions based on our audit objectives. We believe
             that the evidence obtained provides a reasonable basis for our findings
             and conclusions based on our audit objectives.

             Our nation’s critical infrastructure refers to the systems and assets,
Background   whether physical or virtual, so vital to the United States that their
             incapacity or destruction would have a debilitating impact on our nation’s
             security, economic stability, public health or safety, or any combination of
             these factors. DHS has identified 16 critical infrastructure sectors,




             7GAO, Combating Terrorism: Evaluation of Selected Characteristics in National Strategies
             Related to Terrorism, GAO-04-408T (Washington, D.C.: Feb. 3, 2004).
             8GAO, Data Security: Recent K-12 Data Breaches Show That Students Are Vulnerable to
             Harm, GAO-20-644 (Washington, D.C.: Sept. 15, 2020).




             Page 3                                                 GAO-22-105024 K-12 Cybersecurity
including the Dams Sector; the Nuclear Reactors, Materials, and Waste
Sector; and the Government Facilities Sector. 9

In 2013, DHS established the National Plan, to guide protection efforts in
the sectors. The National Plan designated Education Facilities, including
K-12 schools, as a subsector of the Government Facilities Sector. 10 In
addition to educational facilities, the Government Facilities Sector
includes facilities owned or operated by the 56 states and territories,
3,031 counties, 85,973 local governments, 566 federally recognized tribal
nations, and the more than 900,000 public and non-public facilities owned
or operated by the federal government. Collectively, this sector is one of
the largest and most complex sectors within the 2013 National Plan
framework.

The Education Facilities Subsector includes facilities that are owned by
both government and private-sector entities and covers pre-kindergarten
through 12th grade schools, institutions of higher education, and business
and trade schools. 11 According to the K-12 Security Information Exchange
(K12 SIX), a non-profit information sharing organization, K-12 is a $760
billion sector that serves over 50 million students. 12

IT systems supporting our nation’s critical infrastructure—including the
Education Facilities Subsector of the Government Facilities Sector—are
inherently at risk. Systems and networks used by schools are often
interconnected with other internal and external systems and networks,
including the internet. In addition, schools, districts, states, and


9The other sectors include: Chemical; Commercial Facilities; Communications; Critical
Manufacturing; Defense Industrial Base; Emergency Services; Energy; Financial Services;
Food and Agriculture; Healthcare and Public Health; Information Technology;
Transportation Systems; and Water and Wastewater Systems.
10Department of Homeland Security, National Infrastructure Protection Plan 2013:
Partnering for Critical Infrastructure Security and Resilience (Washington, D.C.: December
2013). The National Plan identified 16 critical infrastructure sectors vital to the United
States. In addition, the plan identified the Department of Education as the SRMA and
designated Education Facilities as a subsector of the Government Facilities Sector. The
Education Facilities SSP describes this designation as including K-12 schools.
11The scope of our review was limited to K-12 schools.

12Established in late 2020 as an affiliate of the Global Resilience Federation, K-12 SIX
uses data and analytics tools to help schools prevent cyber threats and mitigate cyber
incidents that occur by providing alerts, reports, document libraries, and discounted
access to security tools.




Page 4                                                   GAO-22-105024 K-12 Cybersecurity
                       educational technology vendors 13, collect and store a range of information
                       about students in these systems and networks. Further, grades, test
                       scores, addresses, telephone numbers, emails, Social Security numbers
                       and medical information are also collected and stored in these systems.
                       With greater connectivity among these systems and networks, threat
                       actors are increasingly motivated to attack these systems for financial
                       gain, to disrupt classes, or for other potentially destructive purposes. 14

Increased Threat of    K-12 schools across the nation face a range of cybersecurity threats.
Cyberattacks at K-12   From 2018 to the present, schools in most states have reported
                       cyberattacks on their systems. 15 In 2020, at least 408 cyber incidents at
Schools
                       K-12 schools were publically reported—an 18 percent increase over the
                       previous year. 16

                       Increased usage of IT by K-12 schools to conduct remote learning, in
                       addition to the IT systems commonly used before the COVID-19
                       pandemic, have increased the potential for a cyberattack as threat actors
                       view schools as opportunistic targets. These threat actors may be
                       motivated by the promise of monetary gain from malware attacks, by the
                       desire to steal data, or simply to cause disruption of K-12 classes. The
                       FBI, CISA and the Multi-State Information Sharing and Analysis Center
                       (MS-ISAC) have noted that threat actors target K-12 remote education to
                       cause disruptions and steal data. 17 Further, the 2019 U.S. Intelligence
                       Community Worldwide Threat Assessment and the 2020 Homeland
                       Threat Assessment state that foreign nations and criminal groups pose




                       13Educational technology vendors provide technological resources to schools such as
                       hardware and software to support teaching and learning in an educational setting.
                       14GAO, Data Security: Recent K-12 Data Breaches Show That Students Are Vulnerable to
                       Harm, GAO-20-644 (Washington, D.C.: Sept. 15, 2020).
                       15Some cyberattacks on K-12 schools may not be publicly reported.

                       16K-12 Cybersecurity Resource Center and the K12 Security Information Exchange, The
                       State of K-12 Cybersecurity: 2020 Year in Review, (Mar. 10, 2021). Incidents were
                       assigned to individual school districts regardless of whether an attack affects one school
                       district or many.
                       17Cybersecurity and Infrastructure Security Agency, Cyber Actors Target K-12 Distance
                       Learning Education to Cause Disruptions and Steal Data, (AA20-345A), (Dec. 10, 2020),
                       accessed March 15, 2021, https://us-cert.cisa.gov/ncas/alerts/aa20-345a.




                       Page 5                                                   GAO-22-105024 K-12 Cybersecurity
the greatest cyberattack threats to critical infrastructure. 18 In addition,
insiders, including students, staff, and vendors, can pose a threat to K-12
security. Table 1 summarizes the various types of threat actors.

Table 1: Cyber Threat Actors

 Threat actor               Description
 Criminal groups            Criminal groups, including organized crime organizations, seek to use
                            cyberattacks for monetary gain. According to the 2020 Homeland
                            Threat Assessment, cybercriminals increasingly target critical
                            infrastructure to generate profit. That assessment also states that
                            criminal organizations often use ransomware—malicious software
                            used to deny access to systems or data—against critical
                            infrastructure entities at the state and local levels by exploiting gaps
                            in cybersecurity.
 Insiders                   Insiders are individuals with authorized access to an information
                            system or enterprise who have the potential to cause harm, wittingly
                            or unwittingly, through destruction, disclosure, or modification of data
                            or through denial of service. Insiders could include system
                            administrators or other knowledgeable employees with privileged
                            access to critical systems, students with authorized access, or
                            contractors with limited system knowledge.
 Nations                    Nations, including groups or programs sponsored or sanctioned by
                            nation states, use cyber tools as part of their information gathering
                            and espionage activities. According to the 2019 Worldwide Threat
                            Assessment of the U.S. Intelligence Community and the 2020
                            Homeland Threat Assessment, China and Russia pose the greatest
                            cyberattack threats; of particular concern, they have the ability to
                            launch cyberattacks that could disrupt or damage critical
                            infrastructure.
 Terrorists                 Terrorists seek to destroy, incapacitate, or exploit critical
                            infrastructures in order to threaten national security, inflict mass
                            casualties, weaken the economy, and damage public morale and
                            confidence. Terrorists could create disruptions by executing denial-of-
                            service attacks against poorly protected networks.
Sources: Summary of GAO, Electricity Grid Cybersecurity: DOE Needs to Ensure Its Plans Fully Address Risks to Distribution Systems,
GAO-21-81 (Washington, D.C.: Mar. 2021), and relevant federal documents. | GAO-22-105024




These threat actors conduct cyberattacks using various methods,
including ransomware, video conferencing disruptions, denial-of-service
attacks, and phishing. Table 2 describes publicly reported examples of
such attacks.


18The 2019 Worldwide Threat Assessment of the U.S. Intelligence Community notes the
cyber risk of terror organizations, in addition to nations and criminal groups. However, the
more recent 2020 Homeland Threat Assessment does not identify terrorists as one of the
top cyber threats facing the nation’s critical infrastructure.




Page 6                                                                           GAO-22-105024 K-12 Cybersecurity
Table 2: Examples of Recent Cyberattacks at Kindergarten through Grade 12
Schools

 Cyberattack                               Description                                Example
 Ransomware                                Ransomware is a type of                    In March 2021, the Broward
                                           malicious software that                    County, Florida school
                                           attempts to block access to                district with more than
                                           a data system and demands                  260,000 students was victim
                                           a fee to be paid in exchange               to a ransomware attack
                                           for restoring access. In                   carried out by a criminal
                                           some instances, the                        group. The group encrypted
                                           attacker may gain access to                the school district’s data and
                                           the data, resulting in a data              demanded a $40 million
                                           breach. They may also sell                 ransom to decrypt the data.
                                           access to valuable student
                                           data to another malicious
                                           actor.
 Video Conferencing                        Video Conferencing                         In September 2020, an
 Disruption                                Disruptions are disruptions                unauthorized individual was
                                           of teleconferences and                     unknowingly admitted to an
                                           online classrooms, often                   elementary school video
                                           with pornographic or hate                  meeting. The individual
                                           images and threatening                     disrupted the meeting for
                                           language.                                  approximately 1 minute by
                                                                                      displaying pornographic
                                                                                      images to students.
 Denial-of-Service                         A Denial-of-Service attack is              In September 2020, the
                                           one that prevents or impairs               Miami-Dade County, Florida
                                           the authorized use of                      school district was victim to
                                           networks, systems, or                      a series of denial-of-service
                                           applications by exhausting                 attacks that disrupted
                                           resources.                                 learning and teaching on the
                                                                                      district’s networks and web-
                                                                                      based systems.
 Phishing                                  Phishing is an attempt to                  In April 2019, the Scott
                                           acquire data or other                      County, Kentucky school
                                           resources through a                        district was victim to a
                                           fraudulent solicitation in                 phishing scam, in which the
                                           email or on a website in                   attacker sent a fraudulent
                                           which the actor pretends to                email disguising themselves
                                           be a reputable person or                   as a vendor. The school
                                           business.                                  district mistakenly paid a
                                                                                      $3.7 million invoice to the
                                                                                      attackers.
Source: GAO analysis of relevant Federal and local government documents, and news articles. | GAO-22-105024




Page 7                                                                         GAO-22-105024 K-12 Cybersecurity
                              We previously reported that K-12 schools and their vendors are
                              increasingly subject to data breaches. 19 These data breaches can include
                              compromises of academic records, students’ personally identifiable
                              information, and health or medical information. Breaches of these types of
                              data can pose significant financial harm to students, as well as physical
                              and emotional harm, if personal information is disclosed to other students.
                              Cyberattacks that are carried out on vendors and partners can have a
                              severe effect, as vendors frequently serve many students across multiple
                              schools.

                              According to data from K12 SIX, K-12 schools publicly reported 62
                              ransomware incidents in 2019, compared to 11 ransomware incidents
                              reported in 2018. 20 In addition, the data notes that 75 percent of all data
                              breaches at K-12 schools in 2020 were carried out on schools’ vendors.
                              These attacks further increased during the COVID-19 pandemic.

                              Further, according to MS-ISAC data, reported ransomware incidents
                              against K-12 schools increased significantly at the beginning of the 2020
                              school year. Specifically, in August and September 2020, 57 percent of all
                              ransomware incidents reported to the MS-ISAC involved K-12 schools,
                              compared to 28 percent of reported ransomware incidents around the end
                              of the previous 2019 school year from January through July of 2020.

Federal Law and Policies      Federal law and public-private plans establish roles and responsibilities
Establish Requirements        for the protection of critical infrastructure, including the Education
                              Facilities Subsector. Key law and policies include the National Defense
for Critical Infrastructure
                              Authorization Act (NDAA) for fiscal year 2021; Executive Order 13636;
Protection                    the National Institute of Standards and Technology (NIST), Framework for
                              Improving Critical Infrastructure Cybersecurity; Presidential Policy
                              Directives 21 and 41; Presidential Decision Directive 63; the National
                              Plan; and the Government Facilities Sector-Specific Plan (SSP). These
                              are discussed in more detail below.

Executive Order 13636         In February 2013, the White House issued Improving Critical
                              Infrastructure Cybersecurity, Executive Order 13636. 21 This order called

                              19GAO, Data Security: Recent K-12 Data Breaches Show That Students Are Vulnerable to
                              Harm, GAO-20-644 (Washington, D.C.: Sept. 15, 2020).
                              20K12 SIX began collecting data on cyber incidents, including ransomware, in 2016 and
                              does not have data prior to that year.
                              21The White House, Improving Critical Infrastructure Cybersecurity, Executive Order
                              13636 (Washington, D.C.: Feb. 12, 2013).




                              Page 8                                                 GAO-22-105024 K-12 Cybersecurity
for a partnership with the owners and operators of critical infrastructure to
improve cybersecurity-related information sharing. To do so, the order
established mechanisms for promoting engagement between federal and
private organizations, including government-coordinating councils that
include federal agencies with responsibilities related to critical
infrastructure protection and sector coordinating councils that include
private-sector entities with roles in protecting critical infrastructure
sectors.

Among other things, the Executive Order designated federal sector-
specific agencies, now renamed as sector risk management agencies
(SRMA) by the fiscal year 2021 NDAA. 22 The SRMAs serve as the lead
agencies for coordinating federally sponsored activities within their
sectors. Further, the order directed DHS, with help from the SRMAs, to
identify and annually review and update a list of critical infrastructures for
which a cybersecurity incident could reasonably result in catastrophic
effects on public health or safety, economic security, or national security.

Executive Order 13636 directed NIST to lead the development of a
flexible performance-based cybersecurity framework that was to include a
set of standards, procedures, and processes. 23 Finally, the order also
directed SRMAs, in consultation with DHS and other interested agencies,
to coordinate with Sector Coordinating Councils to review the
cybersecurity framework and, if necessary, develop implementation
guidance or supplemental materials to address sector-specific risks and
operating environments.



22The William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year
2021 (Fiscal Year 2021 NDAA), Pub. L. No. 116-283, section 9002(a)(7), substituted the
term “Sector Risk Management Agency” for “Sector-Specific Agency” in the definitions in
section 2201(5) of the Homeland Security Act of 2002 (6 U.S.C. § 651(5)). Section 9002
also made conforming amendments and other changes to critical infrastructure sector
designation elsewhere in the Homeland Security Act (see 6 U.S.C. § 652a). The NDAA
also added a new section 2215, Sector Risk Management Agencies, that includes the
responsibilities of those agencies, to the Homeland Security Act (codified at 6 U.S.C. §
665d). See also, 15 U.S.C § 272(e)(3)(B) for definitions of “critical infrastructure” (42
U.S.C. § 5195c(e)) and “Sector-Specific Agency” (now Sector Risk Management Agency)
applicable to NIST’s responsibilities.
23The Cybersecurity Enhancement Act of 2014 authorized NIST to facilitate and support
the development of a voluntary set of standards to reduce cyber risks to critical
infrastructure. 15 U.S.C. § 272(c)(15). The Framework for Improving Critical Infrastructure
Cybersecurity represents that voluntary set of standards.




Page 9                                                   GAO-22-105024 K-12 Cybersecurity
Framework for Improving   In response to Executive Order 13636, NIST first published, in February
Critical Infrastructure   2014, the Framework for Improving Critical Infrastructure Cybersecurity, a
Cybersecurity             voluntary, flexible, performance-based framework of cybersecurity
                          standards and procedures. 24 The framework, which was updated in April
                          2018, outlines a risk-based approach to managing cybersecurity that is
                          composed of three major parts: a framework core, profiles, and
                          implementation tiers. The framework core provides a set of activities to
                          achieve specific cybersecurity outcomes and references examples of
                          guidance to achieve those outcomes.

                          The framework specifies controls that support the core security functions
                          of identifying, protecting, detecting, responding to, and recovering from
                          security incidents. In addition, it specifies that organizations should
                          assess security controls to determine the extent to which the controls are
                          implemented correctly, operating as intended, and producing the desired
                          outcome. Figure 1 lists the five functions and 22 categories of the
                          framework core.




                          24National Institute of Standards and Technology, Framework for Improving Critical
                          Infrastructure Cybersecurity, Version 1.1 (Washington, D.C.: April 2018).




                          Page 10                                                GAO-22-105024 K-12 Cybersecurity
Figure 1: National Institute of Standards and Technology Cybersecurity Framework Functions and Categories




Presidential Directives                 In February 2013, the White House issued Presidential Policy Directive
                                        21 (PPD-21), Critical Infrastructure Security and Resilience, to further
                                        specify critical infrastructure responsibilities. 25 Among other things, PPD-
                                        21 established roles and responsibilities for DHS, the overall lead federal
                                        agency for national policy regarding critical infrastructure security and
                                        resilience, and for SRMAs. PPD-21 required DHS, in coordination with
                                        the SRMAs to (1) develop a description of functional relationships across
                                        the federal government related to critical infrastructure security and
                                        resilience; (2) conduct an analysis and recommend options for improving
                                        public-private partnership effectiveness; and (3) update the National Plan
                                        to include the identification of a risk management framework to
                                        strengthen the security and resilience of critical infrastructure.




                                        25White House, Presidential Policy Directive/PPD-21: Critical Infrastructure Security and
                                        Resilience, (Washington, D.C.: Feb. 12, 2013).




                                        Page 11                                                 GAO-22-105024 K-12 Cybersecurity
In addition, Presidential Policy Directive 41 (PPD-41), United States
Cyber Incident Coordination, sets forth principles governing the federal
government’s response to any cyber incident, whether involving
government or private-sector entities. 26 According to the directive, federal
agencies are to undertake three concurrent lines of effort when
responding to any cyber incident: threat response; 27 asset response; 28
and intelligence support and related activities. 29 In addition, when a
federal agency is an affected entity, the directive states it is to undertake
a fourth concurrent line of effort to manage the effects of the cyber
incident on its operations, customers, and workforce.

Further, in May 1998, the White House issued Presidential Decision
Directive 63, Protecting America’s Critical Infrastructures. 30 The directive
introduced and promulgated the concept of sector-specific Information
Sharing and Analysis Centers (ISACs), which are intended to help critical
infrastructure owners and operators protect facilities, personnel, and
customers from cyber and physical security threats and other hazards.
ISACs are non-profit, member-driven organizations formed by critical
infrastructure owners and operators to share information between
government and industry.


26White House, Presidential Policy Directive/PPD-41: United States Cyber Incident
Coordination (Washington, D.C.: July 26, 2016).
27Threat response activities include conducting appropriate law enforcement and national
security investigative activity at the affected entity’s site; collecting evidence and gathering
intelligence; providing attribution; linking related incidents; identifying additional affected
entities; identifying threat pursuit and disruption opportunities; developing and executing
courses of action to mitigate the immediate threat; and facilitating information sharing and
operational coordination with asset response.
28Asset response activities include furnishing technical assistance to affected entities to
protect their assets, mitigate vulnerabilities, and reduce impacts of cyber incidents;
identifying other entities that may be at risk and assessing their risk of the same or similar
vulnerabilities; assessing potential risks to the sector or region, including potential
cascading effects, and developing courses of action to mitigate these risks; facilitating
information sharing and operational coordination with threat response; and providing
guidance on how best to utilize federal resources and capabilities in a timely, effective
manner to speed recovery.
29Intelligence support and related activities facilitate the building of situational threat
awareness and sharing of related intelligence; the integrated analysis of threat trends and
events; the identification of knowledge gaps; and the ability to degrade or mitigate
adversary threat capabilities.
30White House, Presidential Decision Directive 63: Protecting America’s Critical
Infrastructures (Washington, D.C.: May 22, 1998).




Page 12                                                    GAO-22-105024 K-12 Cybersecurity
The National Defense           The fiscal year 2021 NDAA establishes roles and responsibilities for
Authorization Act for Fiscal   SRMAs in protecting the 16 critical infrastructure agencies in addition to
Year 2021                      those outlined in PPD-21. 31 As established by the NDAA, SRMAs are
                               required to (1) coordinate with DHS and collaborate with critical
                               infrastructure owners and operators, regulatory agencies, and others; (2)
                               support sector risk management, in coordination with CISA; (3) assess
                               sector risk, in coordination with CISA; (4) coordinate the sector, including
                               by serving as a day-to-day federal interface for the prioritization and
                               coordination of sector-specific activities; and (5) support incident
                               management, including supporting CISA, upon request, in asset response
                               activities.

Federal Infrastructure         In response to PPD-21, DHS, with the help of private industry and federal
Protection Plans               agencies within designated sectors, issued an update to the National Plan
                               in 2013. 32 The National Plan, intended as a national guide for the
                               management of risks to critical infrastructure, breaks down the policy
                               requirements in Executive Order 13636 and PPD-21 into risk
                               management-related goals and objectives.

                               According to the National Plan, the critical infrastructure community
                               should work jointly to set specific national priorities. In turn, the national
                               priorities should be supplemented by various sector activities. In addition,
                               the national priorities are to be supported by objectives and priorities
                               developed at the sector level. The National Plan further states that sector
                               objectives and priorities may be articulated in sector-specific plans, which
                               are to serve as targets for collaborative planning between SRMAs and
                               their sector partners.

                               The current version of the Government Facilities SSP was developed in
                               2015 by the General Services Administration (GSA) and DHS in response
                               to PPD-21 and the 2013 version of the National Plan. 33 The Government
                               Facilities SSP was developed to help understand evolving risks and
                               threats such as cyber risk to the Government Facilities Sector’s assets

                               31The William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year
                               2021, Pub. L. No. 116-283, § 9002.
                               32Department of Homeland Security, National Infrastructure Protection Plan 2013:
                               Partnering for Critical Infrastructure Security and Resilience (Washington, D.C.: December
                               2013).
                               33General Services Administration and Department of Homeland Security, Government
                               Facilities Sector-Specific Plan, 2015.




                               Page 13                                                 GAO-22-105024 K-12 Cybersecurity
                           and functions. The GSA and DHS’s Federal Protective Service are to
                           update the Government Facilities SSP based on guidance that CISA
                           provided to the sectors.

Federal Laws Govern        Data privacy and data security are connected concepts. Data privacy is
Student Data Privacy and   the process of appropriately limiting the collection, use, and handling of
                           students’ information, and data security is the process of maintaining the
Security
                           confidentiality, integrity, and availability of student data by an
                           organization, such as a school district. 34 Federal privacy laws may
                           address both data privacy and data security, or focus on either one. Two
                           relevant federal laws pertain to protecting information about students and
                           children: the Family Educational Rights and Privacy Act of 1974
                           (FERPA), 35 which focuses on data privacy, and the Children’s Online
                           Privacy Protection Act of 1998 (COPPA), 36 which addresses both privacy
                           and data security. 37

                           •   The Department of Education is responsible for enforcing FERPA,
                               which addresses the privacy of personally identifiable information in
                               student education records and applies to all schools that receive
                               funds under an applicable program administered by Education. If
                               parents or eligible students believe that their rights under the act have
                               been violated, they may file a formal complaint with Education. In
                               response, Education is required to take appropriate actions to enforce
                               and deal with violations. However, because the department’s authority
                               under FERPA is directly related to the privacy of education records,
                               Education’s security role is limited to incidents involving potential
                               violations of the act.

                           •   COPPA requires the Federal Trade Commission to issue and enforce
                               regulations concerning children’s privacy. The COPPA Rule, which
                               took effect in 2000 and was later amended in 2013, requires operators

                           34The Department of Education stated that it has no legal authority to require general
                           information security standards for K-12 schools and asserted that CISA is the primary
                           federal agency for addressing K-12 cybersecurity. However, as discussed later, CISA is
                           not the primary agency to support cybersecurity protection at K-12 schools but is available
                           to help Education develop needed guidance.
                           3520 U.S.C. § 1232g.

                           3615 U.S.C. §§ 6501-6506.

                           37GAO, Data Security: Recent K-12 Data Breaches Show That Students Are Vulnerable to
                           Harm, GAO-20-644 (Washington, D.C.: Sept. 15, 2020).




                           Page 14                                                 GAO-22-105024 K-12 Cybersecurity
                           of covered websites or online services that collect personal
                           information from children under age 13 to provide notice and obtain
                           parental consent, among other things. 38 COPPA generally applies to
                           the vendors who provide educational technology, rather than to
                           schools. However, according to the Federal Trade Commission
                           guidance, schools can consent on behalf of parents to the collection
                           of students’ personal information if such information is used for a
                           school-authorized educational purpose and for no other commercial
                           purpose. 39

                       In addition to federal laws, state laws set varying requirements for
                       protecting the security of schools and the privacy of personally identifiable
                       information contained in them. 40

                       OSSS, CISA, and the FBI have developed and issued a variety of
Federal Agencies       products and services that are available to the Education subsector to
Have Provided          help protect against cyber threats. However, OSSS has not fully met
                       other responsibilities for providing support to the subsector. Specifically, it
Cybersecurity          has not kept its SSP up-to-date and has not considered whether sector-
Support to K-12        specific guidance is needed to guide schools in implementing the NIST
                       Cybersecurity Framework. Officials from the Department of Education’s
Schools but Have Not   OSSS said that they have no plans to update their SSP because CISA
Kept Plans Up-to-      has not directed them to do so, and OSSS has not determined whether
                       sector-specific guidance is warranted. However, the Department of
Date or Determined     Education is responsible for updating its subsector plan and determining
the Need for Sector-   the need for guidance. Without federal support that is guided by an up-to-
                       date plan and supplemented with appropriate guidance, K-12 schools are
Specific Guidance      less likely to have the federal products, services, and support that can
                       best help protect them from cyberattacks.



                       38The COPPA Rule is codified at 16 C.F.R. Part 312 and implements the Children’s
                       Online Privacy Protection Act of 1998, (15 U.S.C. 6501, et seq.,) which prohibits unfair or
                       deceptive acts or practices in connection with the collection, use, and/or disclosure of
                       personal information from and about children on the Internet.
                       39When schools provide consent on behalf of parents under COPPA, there may be
                       FERPA implications as well. However, an exception to FERPA, known as the “school
                       official exception,” generally applies. This exception permits the disclosure of personally
                       identifiable information from education records, without parental consent, to vendors with
                       whom schools have outsourced institutional services or functions. The exemption also
                       includes restrictions on vendors’ use and disclosure of personally identifiable information.
                       40See for example AR Code § 6-18-109 (Arkansas), CA Educ. Code § 49073.6
                       (California); MD Educ. Code § 4-131 (Maryland); VA Code § 22.1-287.02 (Virginia).




                       Page 15                                                   GAO-22-105024 K-12 Cybersecurity
Federal Agencies Have        Laws and federal guidance establish a framework of roles and
Roles and Responsibilities   responsibilities for OSSS, CISA, and the FBI to support the cybersecurity
                             protection of critical infrastructure, including K-12 schools. The Education
in Supporting the
                             Facilities SSP, an annex to the Government Facilities SSP, designates
Education Facilities         the Department of Education as the SRMA for the Education Facilities
Subsector                    Subsector. Within the Department of Education, OSSS has this role.

                             As the SRMA for the Education subsector, OSSS is required to maintain
                             and update the Education Facilities SSP to, among other things, reflect
                             current risks facing the Education subsector. Guidance requires OSSS to
                             update the SSP every 3 years. OSSS is also required to consult with
                             CISA to make a determination whether sector-specific guidance is
                             needed to guide schools in implementing the NIST Cybersecurity
                             Framework. In addition, leading practices described in GAO’s report on
                             combating terrorism suggest that OSSS, in consultation with CISA,
                             should maintain a current assessment of the risks facing the Education
                             subsector to ensure that federal efforts are appropriately aligned to
                             address current threats. 41

                             While it is not designated as the primary agency to support cybersecurity
                             protection at K-12 schools, CISA has overall responsibility for
                             coordinating with federal and nonfederal entities to identify, analyze,
                             prioritize, and manage strategic risks to the nation’s critical
                             infrastructure. 42 As the lead federal agency for the protection of critical
                             infrastructure, CISA is responsible for providing strategic guidance,
                             promoting a national unity of effort, and coordinating the overall federal
                             effort to promote the security and resilience of critical infrastructure. CISA
                             is also responsible for developing and implementing information sharing
                             programs through which it develops partnerships and shares substantive
                             information with the private sector, and state, local, tribal, and territorial
                             governments. In addition to information sharing initiatives, CISA is tasked
                             with developing resources to help spread awareness about cyber threats,
                             protective measures, and response tactics.

                             The FBI also has a role in providing support to critical infrastructure
                             entities, including K-12 schools. PPD-41 designates the FBI as the lead
                             federal agency for threat response activities, such as investigating

                             41GAO, Combating Terrorism: Evaluation of Selected Characteristics in National
                             Strategies Related to Terrorism, GAO-04-408T (Washington, D.C.: Feb. 3, 2004).
                             42The Cybersecurity and Infrastructure Security Agency Act of 2018 sets responsibilities
                             for CISA. Pub. L. No. 115–278, title XXII, 132 Stat. 4168-4186 (Jan. 3, 2018).




                             Page 16                                                 GAO-22-105024 K-12 Cybersecurity
                           cyberattacks and intrusions across critical infrastructure sectors, including
                           the education subsector. The FBI is responsible for conducting domestic
                           collection, analysis to identify threat actors, and dissemination of cyber
                           threat information. It also is responsible for serving as a focal point for
                           coordinating, integrating, and sharing pertinent information related to
                           cyber threat investigations within the federal government, as appropriate.

OSSS, CISA, and the FBI    OSSS, CISA, and the FBI have provided programs, services, and support
Provide Products,          to assist K-12 schools in protecting and defending against, and
                           responding to cyber threats.
Services, and Support to
Help K-12 Schools          As the SRMA for the Education subsector, OSSS established a
Combat Cyber Threats       Readiness and Emergency Management for Schools Technical
                           Assistance Center to share guidance, training, tools, and resources for K-
                           12 schools and institutions of higher education. In addition, the
                           department’s Office of Planning, Evaluation and Policy Development
                           provides other resources for K-12 schools through its Privacy Technical
                           Assistance Center. Examples of the information provided by these
                           technical assistance centers include:

                           •   Tools developed by schools and higher education emergency
                               managers to improve emergency management, such as sample drills,
                               tabletop exercises, and emergency operations plans, tools and
                               templates.
                           •   Guidance to ensure schools are following cybersecurity best practices
                               for online learning and are adhering to the requirements of the Family
                               Educational Rights and Privacy Act (FERPA) to protect the privacy of
                               students’ personally identifiable information. The privacy technical
                               assistance center also provides a data breach response checklist and
                               training kits to assist schools in evaluating and building incident
                               response processes and plans and to help staff be prepared to
                               respond to data breaches.
                           •   Guidance for parents and students on preparing for cyber threats
                               students face online, including exercises and training to help ensure
                               cyber safety during the COVID-19 pandemic. The emergency
                               management technical assistance center provides a list of resources
                               available from government and private entities on topics such as
                               technology safety online, privacy and safety tips, and tools and
                               resources for children.
                           CISA also provides a variety of products and services to assist K-12
                           schools and other critical infrastructure entities. Key products and
                           services provided by CISA include:


                           Page 17                                         GAO-22-105024 K-12 Cybersecurity
•   Alerts regarding threats to critical infrastructure, including indicators of
    compromise and recommendations for the mitigation of the threat. For
    example, CISA provided an alert regarding disruptions to K-12 remote
    learning classes and data security during the COVID-19 pandemic. 43
    The alert noted that K-12 organizations may be targeted by attacks
    utilizing social engineering or technology vulnerabilities and outlined
    potential mitigations such as best practices for defending against
    ransomware, distributed-denial-of-service, and malware attacks.
•   Incident response assistance upon request, including assessment of
    the root cause of the incident and mitigation steps to restore systems,
    recover from an incident, and prevent future incidents. 44 CISA also
    provides an incident response report based on its assessment that
    includes information regarding the impact of the incident on systems
    and information, and the tools and techniques used by the attacker.
    The report also generally includes a timeline of the attack and the
    activities the attacker carried out on compromised systems.
•   Voluntary assessments and other services, including assessments of
    an entity’s risk management practices as well as vulnerability
    scanning, web application scanning, phishing campaign assessment,
    remote penetration testing, and assessments of an entity’s
    dependencies and risk management practices related to third parties
    and vendors. For example, remote penetration testing simulates the
    tactics and techniques that adversaries may use against an entity’s
    systems to identify areas to exploit.
•   Training exercises, webinars and workshops, including cybersecurity
    awareness webinars and discussions of best practices to help prevent
    incidents and prepare entities to respond if an incident occurs.
•   General guidance on topics such as general cybersecurity threats,
    video conferencing security, and ransomware prevention practices
    and response.
In addition, CISA provides products and services indirectly to K-12
schools through a cooperative agreement with the MS-ISAC, an
independent, non-profit organization that was designated by DHS in 2010
as the cybersecurity ISAC for state, local, tribal, and territorial
governments. The MS-ISAC receives funding from CISA, which it uses to
provide services and information sharing to enhance state, local, tribal,

43This product was co-authored by the FBI, CISA, and MS-ISAC. See appendix II for more
detail.
44CISA only advises organizations on corrective actions, it does not carry out remediation
activities.




Page 18                                                 GAO-22-105024 K-12 Cybersecurity
and territorial governments’ ability to prevent, protect against, respond to,
and recover from cyberattacks and compromises. Products and services
offered by the MS-ISAC include:

•   The Nationwide Cyber Security Review, offered at no cost to MS-
    ISAC members. The review is an annual, self-administered, cyber risk
    assessment intended to help state and local entities assess the
    effectiveness of and identify gaps in their cybersecurity programs and
    initiatives. The review is aligned with the NIST Cybersecurity
    Framework to help entities identify and prioritize actions for reducing
    cybersecurity risks. According to CISA officials we interviewed, 118
    local K-12 organizations participated in the 2019 iteration of this
    review. 45
•   The Malicious Domain Blocking and Reporting service, offered at no
    cost to MS-ISAC members, which can help prevent IT systems from
    connecting to malicious web domains and thus limit infections related
    to malware, ransomware, and phishing. 46 According to the MS-ISAC,
    as of April 2021, 276 of its K-12 members are using this service.
•   An around-the-clock cybersecurity operations center that provides
    information to its members at no cost, including cyber threat
    intelligence and notices about specific cyber incidents that may affect
    members.
•   An around-the-clock network monitoring service known as “Albert”
    that analyzes network traffic of participating members to identify
    threats. According to MS-ISAC officials, fewer than 10 K-12 members
    use the Albert service.
•   Other response services, including emergency conference calls,
    forensic analysis, log analysis, reverse engineering, and analytical
    reports on incidents.
The FBI’s primary function is to conduct threat response activities such as
investigating cyberattacks across the critical infrastructure sectors.
However, the FBI also issues information and alerts about specific cyber
threats targeting state, local, tribal, and territorial governments. The FBI
coordinates with CISA on many of these products. Alerts have included
detailed information of the threat, indicators of compromise, and
recommendations for mitigation. In addition, the FBI offers certain types
45The Nationwide Cyber Security Review is also offered to the Elections Infrastructure
ISAC at no cost, which DHS funds as part of a cooperative agreement.
46The Malicious Domain Blocking and Reporting service is also offered to members of the
Elections Infrastructure ISAC at no cost.




Page 19                                                 GAO-22-105024 K-12 Cybersecurity
of assistance to K-12 schools who are victims of cyberattacks.
Specifically, the FBI can help in attributing the attack to a specific group
or individuals and can conduct analysis to determine what other entities
may be affected by the incident in order to notify them. The FBI collects
and reports information concerning suspected Internet-facilitated criminal
activity on its Internet Crime Complaint Center website. The FBI analyzes
this information to identify emerging threats and new trends, and posts
public service announcements and alerts about the scams.

The products and services offered by CISA, OSSS, and the FBI can be
mapped to the core functions of NIST’s Cybersecurity Framework, which
is intended to aid organizations in their management of cybersecurity risk
and enable risk management decisions. Appendix II shows examples of
products, services, and support provided by CISA, OSSS, and FBI that
correspond to four of the five core functions of the NIST framework. 47

Products and services offered by the MS-ISAC, such as the nationwide
cyber review and the malicious domain blocking service, are available to
all K-12 school districts that are members. There is no cost or other
requirement to be a member, and all resources offered by the MS-ISAC
through funding from CISA are free to members. However, some services
not funded by CISA, such as endpoint security services, penetration
testing, managed security services, and vulnerability management
services are offered at additional cost.

Many school districts that are not members of the MS-ISAC may not have
the opportunity to benefit from the various products and services that it
offers. For example, CISA funds two free Albert Network Monitoring
services for each state. 48 However, officials from the MS-ISAC said that
less than 10 school districts are utilizing Albert. According to MS-ISAC
officials, out of about 15,000 public school districts in the U.S. that are
eligible for membership, only 2,372 have chosen to become members as
of May 2021.




47The examples of resources provided by CISA, OSSS, and the FBI are not exhaustive.
These agencies also provide other products, services, and support that may help address
cybersecurity threats at K-12 schools.
48Albert is a federally funded Intrusion Detection System that provides network security
alerts and helps identify malicious network activity.




Page 20                                                 GAO-22-105024 K-12 Cybersecurity
OSSS Has Not Kept the   While the federal government makes a variety of products and services
Education Facilities    available to the Education subsector to help protect against cyber threats,
                        a key subsector plan is out of date. As previously stated, the fiscal year
Subsector Plan Up-to-
                        2021 NDAA, National Plan, and SSPs establish responsibilities for
Date                    SRMAs. The last-published version of the 2010 Education Facilities SSP
                        requires OSSS to update their SSPs every 3 years. In addition, leading
                        practices described in GAO’s report on combating terrorism state that
                        such a plan should include, among other things, an assessment of the
                        risks facing the areas the strategy is directed toward and a risk
                        assessment that includes an analysis of the threats to, and vulnerabilities
                        of, critical assets and operations. 49 These updates can include changes to
                        the entity’s programs or activities, oversight structure, organizational
                        structure, personnel, technology and physical environments.

                        The Education Facilities SSP was developed and issued in 2010 and has
                        never been updated as an independent document. OSSS officials stated
                        that the most recent update to their SSP is included in an annex of the
                        2015 Government Facilities SSP, which is past the 3-year cycle for SSPs
                        specified in the Education Facilities SSP. Further, the 2010 plan was
                        primarily focused on physical threats to educational facilities, stating that
                        “cyber elements may play a smaller role in the subsector than in other
                        areas.” 50

                        However, since the issuance of this plan over a decade ago, the
                        cybersecurity risks facing the Education Facilities Subsector have rapidly
                        evolved. As we previously stated, K-12 schools across the country have
                        increasingly been targeted for ransomware and other cyberattacks in
                        recent years. Ransomware incidents in 2020 were more severe than in
                        prior years; with the attacks affecting more students, demanding higher
                        ransoms, and causing class and school cancelations. Officials from both
                        CISA and OSSS acknowledged that the cybersecurity risks facing K-12
                        schools have changed since the last issuance of their SSP. Officials from
                        CISA said that cyber incidents, like ransomware, are particularly
                        challenging for K-12 schools because of the schools’ limited resources,
                        lack of qualified IT and security personnel, and difficulties assessing and
                        evaluating risks.


                        49GAO, Combating Terrorism: Evaluation of Selected Characteristics in National
                        Strategies Related to Terrorism, GAO-04-408T (Washington, D.C.: February 2004).
                        50Department of Homeland Security and Department of Education, Education Facilities
                        Sector-Specific Plan: An Annex to the Government Facilities Sector-Specific Plan (2010).




                        Page 21                                                GAO-22-105024 K-12 Cybersecurity
                          OSSS officials stated that while the Department of Education is not in a
                          position to respond directly to cyber threats at the school level, they
                          recognize more can be done in terms of planning for and coordinating the
                          implementation of appropriate information security controls throughout the
                          Education subsector. The officials stated that the department is
                          considering capacity and staffing needs to expand their ability to address
                          cybersecurity threats at K-12 schools. Officials from both CISA and OSSS
                          agreed that the cybersecurity risks facing K-12 schools have changed
                          since the last issuance of their SSP.

                          According to OSSS officials, the department has not worked on updating
                          its SSP for the Education Facilities Subsector because CISA has not
                          directed them to do so. However, as previously stated, the Education
                          Facilities SSP requires OSSS to update their SSP triennially. Without
                          federal support that is guided by an up-to-date plan reflecting current risks
                          and operational circumstances, K-12 schools are less likely to have the
                          federal products, services, and support that can best help protect them
                          from cyberattacks.

OSSS Has Not              Executive Order 13636 directed SRMAs, in consultation with DHS and
Determined the Need for   other interested agencies, to coordinate with the Sector Coordinating
                          Councils to review the NIST Cybersecurity Framework and, if necessary,
Subsector-Specific
                          develop implementation guidance or supplemental materials to address
Guidance                  sector-specific risks and operating environments. The order also directs
                          DHS, in coordination with SRMAs, to establish a voluntary program to
                          support the adoption of the NIST Cybersecurity Framework by owners
                          and operators of critical infrastructure and other entities. 51 The program is
                          intended to enhance critical infrastructure cybersecurity and encourage
                          the adoption of the NIST framework. We previously reported that one of
                          the program’s primary missions is to help sector agencies develop
                          guidance for their respective sectors on how to implement the
                          framework. 52

                          CISA has been promoting the implementation of the NIST Framework as
                          a way to strengthen the management of cyber and physical risks to
                          critical infrastructure. CISA has done this, in coordination with other
                          sectors, by issuing sector-specific guidance to critical infrastructure

                          51The White House, Improving Critical Infrastructure Cybersecurity, Executive Order
                          13636 (Washington, D.C.: Feb. 12, 2013).
                          52Critical Infrastructure Protection: Measures Needed to Assess Agencies’ Promotion of
                          the Cybersecurity Framework, GAO-16-152 (Washington, D.C.: December 2015).




                          Page 22                                                GAO-22-105024 K-12 Cybersecurity
owners and operators so they can better understand and use the
framework to (1) assess and improve their respective sector’s cyber
resiliency; (2) assess their current and target cybersecurity posture; (3)
identify gaps in their existing cybersecurity risk management programs;
and (4) identify sector-specific tools and resources that map to the NIST
Framework. The sectors for which CISA has prepared sector-specific
guidance include Commercial Facilities, Chemical, Emergency Services,
Critical Manufacturing, Dams, and Nuclear. 53

For example, CISA worked with the Commercial Facilities Sector
Coordinating Council and Government Coordinating Council to develop
the Cybersecurity Framework Implementation Guidance that identified
existing cybersecurity tools and resources in the commercial facilities
sector and mapped them to the NIST Framework’s five core functions:
identify, protect, detect, respond, and recover. It identified existing
guidance in the sector such as its Stadium Cybersecurity Best Practices
Guide and mapped it to the governance and risk assessment categories
under the Identify function. 54 It also mapped the sector’s Payment Card
Industry Data Security Standards guidance to the anomalies and events,
security continuous monitoring, and detection processes subcategories
under the Detect function. 55 Mapping cybersecurity tools to the NIST
Framework allows sector operators to identify gaps within their existing
cybersecurity programs, and then plan actions to address those gaps.

Despite increased use and reliance by K-12 schools and other entities in
the Education Facilities Subsector on IT systems and significant recent

53The Department of Homeland Security, CISA, Commercial Facilities Sector
Cybersecurity Framework Implementation Guidance (May 2020); The Department of
Homeland Security, CISA, Chemical Sector Cybersecurity Framework Implementation
Guidance (May 2020); The Department of Homeland Security, CISA, Emergency Services
Sector Cybersecurity Framework Implementation Guidance (May 2020); The Department
of Homeland Security, Critical Manufacturing Sector Cybersecurity Framework
Implementation Guidance (2015); The Department of Homeland Security, Dams Sector
Cybersecurity Framework Implementation Guidance (2015); and the Department of
Homeland Security, Nuclear Sector Cybersecurity Framework Implementation Guidance
for U.S. Nuclear Power Reactors (2015).
54According to the Commercial Facilities Cybersecurity Framework Implementation
Guidance, the Stadium Cybersecurity Best Practices Guide recommends cybersecurity
best practices by examining control systems, enterprise systems, and communication
systems that stadiums and arenas typically rely on for essential operations.
55According to the Commercial Facilities Cybersecurity Framework Implementation
Guidance, the Payment Card Industry Data Security Standards guidance establishes
worldwide security standards to help organizations that process card payments prevent
credit card fraud through increased controls around data and its exposure to compromise.




Page 23                                                GAO-22-105024 K-12 Cybersecurity
              cyberattacks, OSSS has not assessed the need for, or consulted with
              CISA on, developing sector-specific guidance for implementing the NIST
              Cybersecurity Framework. CISA officials stated that they are available to
              help develop sector-specific implementation guidance for the Education
              sector but that OSSS, as the SRMA for the subsector, must make the
              determination that such guidance is needed to address the subsector’s
              risks and operating environment. The CISA officials noted that other
              resources are available through the MS-ISAC that K-12 schools can
              utilize to measure the maturity of their cyber risk management practices,
              such as the nationwide review self-assessment process, which is based
              on the NIST Framework. However, as mentioned previously, relatively
              few K-12 school districts are members of the MS-ISAC.

              OSSS officials said that the department has not made a determination
              about the need for sector-specific guidance because it relies on CISA to
              develop guidance related to information security and believes CISA
              should make such a determination. However, as CISA officials pointed
              out, OSSS is the SRMA for the subsector and thus is responsible for
              making the determination. Without a determination of whether sector-
              specific guidance is needed, OSSS may be less able to assist K-12
              schools in protecting against cyber threats, and as a result, schools may
              be less able to prevent and respond to cyberattacks.

              The Department of Education’s OSSS, CISA, and FBI have provided a
Conclusions   variety of products, services, and guidance to assist K-12 schools in
              protecting, defending, and responding to cyber threats. However, OSSS
              has not undertaken a planning effort to assess changes to the risks facing
              the Education subsector and how federal assistance priorities could be
              updated to best meet current needs. While the 2010 SSP states that
              cyber may play a smaller role in the Education subsector, schools have
              been increasingly targeted for ransomware and other cyberattacks. As a
              result, OSSS lacks an up-to-date plan based on a current assessment of
              the cybersecurity risks facing the subsector.

              Although the cybersecurity risks facing the subsector have increased
              significantly, the Department of Education has not consulted with CISA to
              make a determination on whether sector-specific guidance is needed for
              K-12 schools to help protect against those risks. As a result, OSSS may
              be unable to determine whether the products, services, and support
              currently being offered by the federal government best meet the needs of
              the Education subsector in protecting K-12 schools from cyber threats.
              Given that significant numbers of ransomware and other cyberattacks are
              disrupting school operations and threatening the privacy and security of


              Page 24                                       GAO-22-105024 K-12 Cybersecurity
                      student information, it is critical that the federal government’s actions be
                      tailored to achieve the greatest possible protection for K-12 schools and
                      students.

                      We are making the following two recommendations to Education:
Recommendations for
Executive Action      The Secretary of Education should initiate a meeting with the Director of
                      CISA to determine how to update its sector-specific plan (SSP) for the
                      Education subsector. The plan should assess and prioritize federal
                      actions to assist K-12 schools in protecting themselves from cyberattacks.
                      (Recommendation 1)

                      The Secretary of Education should make a determination, in consultation
                      with the Director of CISA and based on current cybersecurity risks, on
                      whether subsector-specific guidance is needed for the Education
                      subsector. (Recommendation 2)

                      We provided a draft of this report to the Department of Education, CISA,
Agency Comments       and FBI. In response, we received written comments on the draft from the
and Our Evaluation    Department of Education. In addition, all three agencies provided
                      technical comments, which we have incorporated in the report, as
                      appropriate.

                      In its comments (reprinted in appendix III), Education concurred with our
                      recommendations, but expressed concerns with how they were to be
                      implemented. The department stated that it has no legal authority to
                      require general information security standards for K-12 schools and that
                      CISA is the primary federal agency for addressing K-12 cybersecurity.
                      The department also stated that, in the area of information security, its
                      authority outside of privacy is generally limited to supporting the efforts of
                      CISA.

                      We do not believe these assertions are inconsistent with our
                      recommendations. However, we revised our recommendation language
                      as well as language in the report to address the department’s concerns.
                      The actions of updating the subsector plan for the Education subsector
                      and determining whether subsector guidance is needed do not require the
                      department to develop information security standards or take other
                      unauthorized actions regarding information security. The department’s
                      role is to develop a plan for the Education subsector and to make a
                      determination about the need for more guidance.




                      Page 25                                          GAO-22-105024 K-12 Cybersecurity
Regarding our first recommendation, the department stated that it would
work to update its sector plan at the direction of, and with guidance from,
CISA with consideration of its limited role and authority to act within the
subsector. However, as described in the report, Education’s OSSS is the
lead for this action. As the SRMA for the Education subsector, OSSS is
required to maintain and update the Education Facilities SSP to, among
other things, reflect current risks facing the Education subsector.
Guidance requires OSSS to update the SSP every 3 years. We continue
to believe OSSS should take the lead to update the SSP in coordination
with CISA.

In addition, although the department concurred with our recommendation
to consult with CISA and to make a determination whether guidance is
needed for the subsector, it reiterated that it does not have specific
authority to issue information security guidance. We agree that the
Department of Education’s authority is limited to privacy. However, as
discussed in the report, Education is the lead SRMA for the subsector
and is thereby responsible for determining the need for additional
guidance. Contrary to Education’s assertion, DHS’s CISA is not the
primary agency to support cybersecurity protection at K-12 schools but is
available to help develop needed guidance once OSSS, as the SRMA for
the subsector, makes the determination that such guidance is needed.

As agreed with your offices, unless you publicly announce the contents of
this report earlier, we plan no further distribution until 30 days from the
report date. At that time we will send copies of this report to appropriate
congressional committees, the Secretary of Education, the Secretary of
Homeland Security, and the Attorney General of the United States. In
addition, the report is available at no charge on the GAO website at
https://www.gao.gov.




Page 26                                        GAO-22-105024 K-12 Cybersecurity
If you or your staff members have any questions about this report, please
contact Nick Marinos at (202) 512-9342 or marinosn@gao.gov. Contact
points for our Offices of Congressional Relations and Public Affairs may
be found on the last page of this report. GAO staff who made major
contributions to this report are listed in appendix IV.




Nick Marinos
Director, Information Technology and Cybersecurity




Page 27                                      GAO-22-105024 K-12 Cybersecurity
List of Requesters

The Honorable Margaret Wood Hassan
Chair
Subcommittee on Emerging Threats and Spending Oversight
Committee on Homeland Security and Governmental Affairs
United States Senate

The Honorable Kyrsten Sinema
Chair
Subcommittee on Government Operations and Border Management
Committee on Homeland Security and Governmental Affairs
United States Senate

The Honorable Jacky Rosen
United States Senate




Page 28                                  GAO-22-105024 K-12 Cybersecurity
Appendix I: Objective, Scope, and
              Appendix I: Objective, Scope, and
              Methodology


Methodology

              Our objective was to determine the extent to which federal agencies have
              assisted kindergarten through grade 12 (K-12) schools in protecting
              themselves from cyber threats.

              To address this objective, we examined relevant laws and federal
              guidance that specify the roles and responsibilities of the Department of
              Homeland Security’s Cybersecurity and Infrastructure Security Agency
              (CISA), the Department of Education’s Office of Safe and Secure Schools
              (OSSS), and the Federal Bureau of Investigation (FBI) to assist schools in
              protecting against cyber threats. These laws and guidance include the
              relevant parts of the National Defense Authorization Act for Fiscal Year
              2021, 1 the National Infrastructure Protection Plan, 2 the Government
              Facilities Sector-Specific Plan, 3 the Education Facilities Sector-Specific
              Plan, 4 Presidential Policy Directive 21, 5 Presidential Policy Directive 41, 6
              Executive Order 13636, 7 the National Institute of Standards and
              Technology (NIST) Framework for Improving Critical Infrastructure
              Cybersecurity, 8 and Presidential Decision Directive 63. 9

              We also interviewed officials from these agencies to obtain information
              and documentation about the programs, services, and products they offer

              1The William M. (Mac) Thornberry National Defense Authorization Act for Fiscal Year
              2021, Pub. L. No. 116-283, § 9002.
              2Department of Homeland Security, National Infrastructure Protection Plan 2013:
              Partnering for Critical Infrastructure Security and Resilience (Washington, D.C.: December
              2013).
              3General Services Administration and Department of Homeland Security, Government
              Facilities Sector-Specific Plan, 2015.
              4Department of Education and Department of Homeland Security, Education Facilities
              Sector-Specific Plan, 2010.
              5White House, Presidential Policy Directive/PPD-21: Critical Infrastructure Security and
              Resilience (Washington, D.C.: Feb. 12, 2013).
              6White House, Presidential Policy Directive/PPD-41: United States Cyber Incident
              Coordination (Washington, D.C.: July 26, 2016).
              7The White House, Improving Critical Infrastructure Cybersecurity, Executive Order 13636
              (Washington, D.C.: Feb. 12, 2013).
              8National Institute of Standards and Technology, Framework for Improving Critical
              Infrastructure Cybersecurity, Version 1.1 (Washington, D.C.: April 16, 2018).
              9White House, Presidential Decision Directive 63: Protecting America’s Critical
              Infrastructures (Washington, D.C.: May. 22, 1998).




              Page 29                                                 GAO-22-105024 K-12 Cybersecurity
Appendix I: Objective, Scope, and
Methodology




to assist K-12 schools to combat cyber threats, such as training exercises
to prepare staff for cyber incident response, alerts and notifications of
cyber threats, recommendations for cyber safety, and network monitoring
tools. We analyzed this documentation, including FBI Private Industry
Notifications and alerts, reports on Multi-State Information Sharing and
Analysis Center (MS-ISAC) and CISA’s Malicious Domain Blocking and
Reporting service, and other documents to identify the purpose of each
program, service, or product.

We compared the programs, services, and products these agencies offer
to assist schools in combating cyber threats with the roles and
responsibilities of the agencies as defined in the previously identified law,
and guidance to determine whether there were any gaps in the agencies’
efforts to fulfill their roles and responsibilities. In addition, we compared
planning documents, such as the Education Facilities and Government
Facilities Sector-Specific Plans (SSPs) to GAO’s key characteristics of a
national strategy to further identify gaps in the agencies’ efforts to fulfill
their roles and responsibilities in supporting the Education subsector. 10

In addition, we identified significant cybersecurity threats facing the
Education subsector by analyzing data from K-12 Security Information
Exchange (K-12 SIX), a non-profit information sharing organization,
regarding significant K-12 cyber incidents that were analyzed in a prior
GAO report. 11 For this report, we analyzed the data to identify significant
incidents that occurred in each state between 2018 and 2020 and
determine the scope of incidents during this time. In addition, we
interviewed officials from federal agencies and the MS-ISAC to obtain
information about the types of cyber incidents that were reported by K-12
schools from 2018 to present.

We further reviewed and analyzed the Education Facilities SSP to
determine the extent to which it reflected an up-to-date plan that
addressed those and other cybersecurity threats in the subsector that
were identified from the K-12 SIX data. To do so, we compared the
department’s last planning effort to federal requirements for updating
agency SSPs. In addition, we interviewed OSSS and CISA agency
officials to identify whether any sector-specific guidance was developed to

10GAO, Combating Terrorism: Evaluation of Selected Characteristics in National
Strategies Related to Terrorism, GAO-04-408T (Washington, D.C.: Feb. 3, 2004).
11GAO, Data Security: Recent K-12 Data Breaches Show That Students Are Vulnerable to
Harm, GAO-20-644 (Washington, D.C.: Sept. 15, 2020).




Page 30                                                GAO-22-105024 K-12 Cybersecurity
Appendix I: Objective, Scope, and
Methodology




address subsector risks and operating environment. We discussed our
assessment of the subsector plan with OSSS and CISA agency officials
to determine the reasons for apparent gaps in agency planning efforts.

We conducted this performance audit from February 2021 to October
2021, in accordance with generally accepted government auditing
standards. Those standards require that we plan and perform the audit to
obtain sufficient, appropriate evidence to provide a reasonable basis for
our findings and conclusions based on our audit objectives. We believe
that the evidence obtained provides a reasonable basis for our findings
and conclusions based on our audit objectives.




Page 31                                      GAO-22-105024 K-12 Cybersecurity
Appendix II: Federal Products, Services, and
                                          Appendix II: Federal Products, Services, and
                                          Support


Support

                                          Table 3 maps the products, services, and support provided by the
                                          Cybersecurity and Infrastructure Security Agency (CISA), the Department
                                          of Education’s Office of Safe and Supportive Schools and Office of
                                          Planning, Evaluation, and Policy Development, and the Federal Bureau of
                                          Investigation (FBI) that correspond to four of the five core functions of the
                                          National Institute of Standards and Technology (NIST) Cybersecurity
                                          Framework. These agencies also provide other products, services, and
                                          support that may help address cybersecurity threats at kindergarten
                                          through grade 12 schools.

Table 3: Federal Products, Services, and Support That Address National Institute of Standards and Technology Framework
Functions for the Education Facilities Subsector

Framework
Core Function    Description                                    Agency             Related Product, Service, or Support
Identify         Identify cybersecurity risks to systems,         FBI, CISA, and   Alert regarding cyber threats to K-12 remote
                 people, data, and capabilities in the context of MS-ISAC:         learninga
                 the school to prioritize their efforts.
                                                                  CISA             Assessments and cybersecurity services (e.g.
                                                                                   risk management practices as well as
                                                                                   vulnerability scanning, web application scanning,
                                                                                   phishing campaign assessment, remote
                                                                                   penetration testing, and assessments of an
                                                                                   entity’s connections to third parties and vendors)
                                                                MS-ISAC            Nationwide Cybersecurity Review
                                                                                   Cybersecurity Operations Center
                                                                Education          Guidance for parents and students regarding
                                                                                   cyber threats during online learning (e.g.
                                                                                   resources on technology safety online, privacy
                                                                                   and safety tips, and tools and resources for
                                                                                   children)b
                                                                FBI                Internet Crime Complaint Center Annual
                                                                                   Cybercrime Reportc
                                                                                   Private Industry Notificationsd
                                                                                   Alertse
Protect          Protect the schools systems, people, data,     CISA               Guidance for schools using video conferencing
                 and capabilities through appropriate                              and ransomware prevention practicesf
                 safeguards and limits or contain the impact of                    Training exercises, webinars and workshops,
                 a potential cybersecurity event.                                  including cybersecurity awareness webinars and
                                                                                   discussions of best practices to help prevent
                                                                                   incidents
                                                                CISA and MS-       Malicious Domain Blocking and Reporting
                                                                ISAC
                                                                Education          Family Educational Rights and Privacy Act and
                                                                                   Online Learning Security Best Practicesg




                                          Page 32                                                  GAO-22-105024 K-12 Cybersecurity
                                                               Appendix II: Federal Products, Services, and
                                                               Support




 Framework
 Core Function              Description                                                       Agency             Related Product, Service, or Support
                                                                                                                 Virtual library of tools for cyber emergency
                                                                                                                 management (e.g. sample drills, tabletop
                                                                                                                 exercises, and emergency operations plans,
                                                                                                                 tools and templates)
                                                                                                                 Data breach response training kit
 Detect                     Detect cyberattacks in an effective and timely CISA and MS-                          Albert Network Monitoring Resources
                            manner, using appropriate activities like      ISAC
                            continuous monitoring capabilities or
                            detection processes.
 Respond                    Respond to a cyberattack using processes to CISA                                     Response services (e.g. recommendations for
                            take action regarding a cybersecurity incident                                       remediation and future prevention, and incident
                            and contain the impact of such an incident.                                          response reports)
                                                                                              MS-ISAC            Response services (e.g. reverse engineering, log
                                                                                                                 analysis, emergency conference calls, forensic
                                                                                                                 analysis, recommendations for mitigation)
                                                                                              Education          Data breach response check listh
                                                                                              FBI                Incident response, attribution and analysis

Legend: CISA=Cybersecurity and Infrastructure Security Agency;
FBI=Federal Bureau of Investigation;
MS-ISAC= Multi-State Information Sharing and Analysis Center;
K-12=kindergarten through grade 12
Source: GAO analysis of CISA, OSSS, and FBI resources to combat cyber threats at K-12 schools. | GAO-22-105024
                                                               a
                                                                Federal Bureau of Investigation, the Cybersecurity and Infrastructure Security Agency, and the Multi-
                                                               State Information Sharing and Analysis Center, Cyber Actors Target K-12 Distance Learning
                                                               Education to Cause Disruptions and Steal Data (AA20-345A), Dec. 10, 2020, accessed March 15,
                                                               2021, https://us-cert.cisa.gov/ncas/alerts/aa20-345a.
                                                               b
                                                                Department of Education, Cyber Safety Quick Links For Protecting Youth: Empowering Students to
                                                               Become Responsible Digital Citizens and Engage Online Safely.
                                                               c
                                                                   Federal Bureau of Investigations, Internet Crime Report 2020.
                                                               d
                                                                Federal Bureau of Investigation, FBI FLASH: Increase in PYSA Ransomware Targeting Education
                                                               Institutions (CP-000142-MW), (Mar. 16, 2021).
                                                               e
                                                                Federal Bureau of Investigation, FBI Private Industry Notification: Business Email Compromise
                                                               Actors Targeting State, Local, Tribal and Territorial Governments Straining Resources (20210317-
                                                               001), (Mar. 17, 2021).
                                                               Cybersecurity and Infrastructure Security Agency, Video Conferencing: Guidelines to Keep you and
                                                               f

                                                               Your Students Safe, (May. 13, 2020).
                                                               g
                                                                Department of Education, Student Privacy Policy Office: FERPA and Virtual Learning Related
                                                               Resources, (Mar. 2020).
                                                               h
                                                                   Department of Education, PTAC, Data Breach Response Checklist, (Sept. 2012).




                                                               Page 33                                                             GAO-22-105024 K-12 Cybersecurity
Appendix III: Comments from the
              Appendix III: Comments from the Department
              of Education


Department of Education




              Page 34                                      GAO-22-105024 K-12 Cybersecurity
Appendix III: Comments from the Department
of Education




Page 35                                      GAO-22-105024 K-12 Cybersecurity
Appendix III: Comments from the Department
of Education




Page 36                                      GAO-22-105024 K-12 Cybersecurity
Appendix IV: GAO Contacts and Staff
                  Appendix IV: GAO Contacts and Staff
                  Acknowledgments


Acknowledgments

                  Nick Marinos, (202) 512-9342 or marinosn@gao.gov
GAO Contacts
                  In addition to the contact named above, John de Ferrari (Assistant
Staff             Director), Kavita Daitnarayan (Analyst-In-Charge), Anna Bennett, Chris
Acknowledgments   Businsky, Donna Epler, Jennifer Gregory, Ahsan Nasar, Walter Vance,
                  and Drew Yarbrough made key contributions to this report.




(105024)
                  Page 37                                      GAO-22-105024 K-12 Cybersecurity
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