Order parameters and phenomenological theory for both high- and low-symmetry biaxial nematic phases are presented and it is predicted that the chiral low-symmetry biaxial phase must be ferroelectric. This conclusion is based on general symmetry arguments and on the results of the Landau-de Gennes theory. The microscopic mechanism of the ferroelectric ordering in this chiral biaxial phase is illustrated using a simple molecular model based on dispersion interactions between biaxial molecules of low symmetry. Similar to the chiral smectic C* phase, the ferroelectricity in the chiral biaxial nematic phase is improper, i.e., polarization is not a primary order parameter and is not determined by dipolar interactions. Ferroelectric ordering in bi...