Vulnerability Disclosure Policy - January 12, 2021

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Vulnerability
Disclosure Policy

     January 12, 2021
Table of Contents
Introduction                                             3
Authorization                                            3
Guidelines                                               3
Test Methods                                             4
Scope                                                    4
Reporting a Vulnerability                                4
Disclosure                                               5
Questions                                                5

Vulnerability Disclosure Policy | January 12, 2021   2
Introduction
The Millennium Challenge Corporation (“MCC”) is committed to ensuring the security of the American
public by protecting their information. This policy is intended to give security researchers clear guidelines
for conducting vulnerability discovery activities and to convey our preferences in how to submit
discovered vulnerabilities to us.

This policy describes what systems and types of research are covered under this policy, how to send us
vulnerability reports, and how long we ask security researchers to wait before publicly disclosing
vulnerabilities.

We encourage you to contact us to report potential vulnerabilities in our systems.

For reports submitted in compliance with this policy, the MCC will acknowledge receipt within ten (ten)
business days, endeavor to timely validate submissions, implement corrective actions if appropriate, and
inform researchers of the disposition of reported vulnerabilities.

Authorization
If you make a good faith effort to comply with this policy during your security research, we will consider
your research to be authorized, we will work with you to understand and resolve the issue quickly, and
MCC will not recommend or pursue legal action related to your research. Should legal action be initiated
by a third party against you for activities that were conducted in accordance with this policy, we will make
this authorization known.

Guidelines
Under this policy, “research” means activities in which you:

         Notify us as soon as possible after you discover a real or potential security issue.
         Make every effort to avoid privacy violations, degradation of user experience, disruption to
         production systems, and destruction or manipulation of data.
         Only use exploits to the extent necessary to confirm a vulnerability’s presence. Do not use an
         exploit to compromise or exfiltrate data, establish command line access and/or persistence, or use
         the exploit to pivot to other systems.
         Provide us a reasonable amount of time to resolve the issue before you disclose it publicly.
         Do not submit a high volume of low-quality reports.

Once you have established that a vulnerability exists or encounter any sensitive data (including personally
identifiable information, financial information, or proprietary information or trade secrets of any party),

Vulnerability Disclosure Policy | January 12, 2021                                                      3
you must stop your test, notify us immediately, and not disclose this data to anyone outside of your
organization, or publicly until you follow the ‘Disclosure’ section below.

Test Methods
The following test methods are not authorized:

      a. Test any system other than the systems set forth in the ‘Scope’ section below.
      b. Disclose vulnerability information except as set forth in the ‘Reporting a Vulnerability’ and
          ‘Disclosure’ sections below.
      c. Engage in physical testing of facilities or resources.
      d. Engage in social engineering.
      e. Send unsolicited electronic mail to MCC users, including “phishing” messages.
      f. Execute or attempt to execute a denial of service (DoS) attack, a distributed denial of service
          (DDoS) attack, attempt any type of resource exhaustion attack on MCC networks or systems.
          Intentionally or unintentionally impair, disrupt, or disable MCC networks or systems, or test in a
          manner which could degrade the operation of MCC networks or systems.
      g. Introduce malicious software.
      h. Test third-party applications, websites, or services that integrate with or link to or from MCC
          systems.
       i. Delete, alter, share, retain, or destroy MCC data, or render MCC data inaccessible, or, use an
          exploit to exfiltrate data, establish command line access, establish a persistent presence on MCC
          systems, or “pivot” to other MCC systems.

Security researchers may:

View or store MCC nonpublic data only to the extent necessary to document the presence of a potential
vulnerability.

Security researchers must:

      a. cease testing and notify us immediately upon discovery of a vulnerability,
      b. cease testing and notify us immediately upon discovery of an exposure of nonpublic data, and,
      c. purge any stored MCC nonpublic data upon reporting a vulnerability.

Scope
The following systems / services are in scope:

      a. www.mcc.gov, and all subdomains of mcc.gov;

Any services not explicitly listed above are excluded from scope. Additionally, vulnerabilities found in non-
federal systems from our vendors fall outside of this policy’s scope and should be reported directly to the
vendor according to its disclosure policy (if any).

Vulnerability Disclosure Policy | January 12, 2021                                                       4
Reporting a Vulnerability
Reports are accepted via electronic mail at vulnerabilitydisclosure@mcc.gov. Acceptable message formats
are plain text, rich text, and HTML.

Reports should provide a detailed technical description of the steps required to reproduce the
vulnerability, including a description of any tools needed to identify or exploit the vulnerability. Images
(e.g., screen captures), and other documents may be attached to reports. It is helpful to give attachments
illustrative names. Reports may include proof-of-concept code that demonstrates exploitation of the
vulnerability. We request that any scripts or exploit code be embedded into non-executable file types. We
can process all common file types and file archives; including, zip, 7zip, and gzip.

Researchers may submit reports anonymously or provide contact information in any preferred method or
time of day they see fit to communicate. We may contact researchers to clarify reported vulnerability
information or other technical interchange.

By submitting a report to the MCC, researchers warrant that the report and any attachments do not
violate the intellectual property rights of any third party and the submitter grants the MCC a non-
exclusive, royalty-free, world-wide, perpetual license to use, reproduce, create derivative works, and
publish the report and any attachments.

MCC will provide no monetary award, intention to advertise or give public credit to Researchers for
identification of vulnerabilities.

Disclosure
The MCC is committed to timely correction of vulnerabilities. However, we recognize that public
disclosure of a vulnerability in absence of a readily available corrective action likely increases versus
decreases risk. Accordingly, we require that you refrain from sharing information about discovered
vulnerabilities for 90 calendar days after you have received our acknowledgement of receipt of your report,
or until you receive notice that MCC has remediated the vulnerability, whichever comes first. If you
believe others should be informed of the vulnerability prior to our implementation of corrective actions,
we require that you coordinate in advance with us.

We may share vulnerability reports with the Cybersecurity and Infrastructure Security Agency (CISA),
other U.S. Government agencies, and vendors. We will not share names or contact data of security
researchers, unless given explicit permission, or required by law or regulation.

Questions

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Questions regarding this policy may be sent to vulnerabilitydisclosure@mcc.gov. The MCC encourages
                                   security researchers to contact us for clarification on any element of this policy. Please contact us prior to
                                   conducting research if you are unsure if a specific test method is inconsistent with or unaddressed by this
                                   policy. We also invite security researchers to contact us with suggestions for improving this policy.

                                   Vulnerability Disclosure Policy | January 12, 2021                                                        6
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