Rmogull of Securosis and Gunnar Peterson claim that GRC is dead.  In my typical global-brained style, I want to cut to the root cause of why GRC is stillborn.

As a group, we need to come to the concensus that half of the security industry is a bunch of spam-sending FUD-mongering dotcom dropouts with MBAs who see the “perfect storm” of money and opportunity that an uncertain-but-necessary niche market brings.  Furthermore, I say we distance ourselves from them because they make the rest of us look bad.

Failed parking meter by cgansen. 

These are the same people who pitched technical policy compliance solutions for SOX which became continuous compliance which begat risk management which begat GRC.  Do we really need all this cr*p?

Look at the warning signs of this half of the industry, these were so true for the dotcom era:

• New companies qnd products you’ve never heard of
• Staff nobody’s ever heard of
• “Trendy” product class that everybody wants to do this year
• Claim to have product purchased by a “Major Financial Institution”
• Is a rebranding of a previously-failing product
• Company was not security-focused last year
• Company and product life-span of ~2 years
• No alignment with other vendors or industry leaders
• Technology is “hoaky”–SIEM solutions using MS Access as the back-end
• Feels “gimmicky”

If you see any of these in a perspective vendor, run away now!  And if you do buy, don’t say I didn’t warn you.

Now, in a past life, SSG Rybolov would say something witty like how people who are used to preventing and detecting fraud should be able to come up with a model to keep people from invading the industry looking for the filthy lucre.  In fact, I think I just might have.  =)

The other half of you all, the non-snake-oil-selling half, is great, keep up the good work and never, ever go to the dark side.

• How to Not Let FISMA Become a Paperwork Exercise
• Engagement Economics and Security Assessments
• An Open Letter to the Next President of the United States
• When the News Breaks, We Fix it…
• “Machines Don’t Cause Risk, People Do!”

I have a very disturbing trend with comments to my blog:  I don’t get any comments on the serious stories–only the “fun” posts.

This leads me to believe one of the following is at play:

• I write succinctly and with authority and never make mistakes. (at least it helps to hope…)
• Nobody knows the subjects that I talk about because it’s a niche to a niche.
• I don’t sensationalize the news enough to make people want to comment.  Note that this is a radical departure from the mainstream media when it comes to security and government, where FUD-mongering is the norm.
• People are scared of me because they think I’m intellectually and emotionally unstable and that I’m going to trash them if they comment.  =)
• Government employees are afraid to put anything critical of their leadership in writing.
• Like they say about the classified world, “Those who know don’t talk, those who talk don’t know”. (side note:  what am I saying about myself here?)
• The First Rule of FISMA Club is that YOU DO NOT TALK ABOUT FISMA CLUB!!!111oneoneone
• If it’s your first comment, you have to fight.

Blog Explanation in French by Stephanie Booth

Now the problem for me is that in order to make security in the government work, we need to change the culture of the people doing it.  IT and specifically security require a zero-defects approach, and this is counter to survivability in a political environment.  The only way we can do that is if I’m not the only voice preaching in the wilderness–I really do want people to tell me I’m full of it and give a good rationale.  =)

In the spirit of helping, this is the Guerilla’s Guide to Commenting on http://www.guerilla-ciso.com/

• Everything in Moderation:  No big surprise–I moderate comments.  This is pretty much so I can keep the spam out.  I’ve only had one legitimate post that I deleted because it was personal in nature from a person who knew me in “a past life”.
• Email is Semi-Anonymous:  If you post a comment using a bogus email address, I’m happy with it as long as the content is relevant and doesn’t look like spam.  The email address is really only so wordpress can track you and automagically approve your next post as long as the name and email match up.
• Thou Shalt Remember the Chatham House Rule:  I do not repeat anything that was told to me in confidence.  Neither should you.  Yes, there are things I won’t write on here, like the conversation I had with [censored] from [censored] who confirmed that [censored]-[censored] is not yet final because [censored].
• I’m Neither a Crook Nor a Cop:  I have yet to receive any kind of subpoena asking for subscriber or commenter information, nor do I send you stupid spam jokes because I know who you are.

I’ll end with one of my favorite army jokes:  “What’s the difference between a war story and a fairy tale?  A fairy tale begins with ‘Once upon a time’, war stories begin with ‘No sh*t, there I was'”.

• On Government Employees, Culture, and Survivability
• The Press has Me all Confused
• My Blog is Dead, Long Live My Blog!
• On Why I Blog… FUD is the Reason for the Writin’
• A Funny Thing Happened Last Week on Capital Hill

I’ve said it a million times before:  I don’t care if you switch to $FooFramework, as long as you have the same people executing it with the same skillset, the results will be the same.  Last week and for the near-term, it’s a new bill to replicate the tenets of FISMA and the NIST framework thereof.

Last week, Representative Langevin introduced HR 5983, the “Homeland Security Network Defense and Accountability Act of 2008”.  Some press on the bill:

• Security Focus
• Committee on Homeland Security

Now the big question for me on this bill (and really, any proposed law) is this:  How does this provide anything above and beyond what is already required by FISMA, OMB policies, and NIST guidelines?  My short analysis:  Not much, and Rep Langevin is just “stirring the pot” with the big spoon of politics.

HR 5983 requires the following:

• Re-establishes the role and staffing requirements for the CIO, including network monitoring
• Testing the DHS networks using “attack-based” protocols
• IG audits and reporting
• Adding responsibility for contractor systems

Again, nothing new here that isn’t required already.  The only benefit to this bill that I see is that if it’s law, the Executive Branch has to request the funding in their budget request and Congress has to (maybe) fund it. It isn’t that DHS doesn’t have the in-house expertise–they own US-CERT.  It’s not that they have a lack of smart people–they own the Security Line of Business.  It’s that there are only so many hours in the day to get things done, and DHS has had lots of work since their creation in 2002.

A little bit of peeking behind the security kimono at DHS is in order.  DHS consists of subagencies, known as Operational Elements, such as TSA, ICE, CBP, etc.  The heads of these agencies are peers to the DHS CIO and have their own CIO and CISO, even though that’s not what they’re called.  See, the OEs do not have to listen to the DHS CIO, and that’s a huge problem.  Last year, DHS made the DHS CIO the budget approver for the OE’s IT budgets, which is a step forward, but still there is much room for improvement.  That’s something that Congress can fix.

Now it just isn’t a “Government IT Security News Day” without a comment from Alan Paller of SANS fame…

“One story is missing from this issue because the press hasn’t picked it up yet. Under Chairman Langevin of Rhode Island, the US House of Representatives Subcommittee on Emerging Threats and Cybersecurity just approved a new bill that changes how security will be measured, at least at the Department of Homeland Security. This is the beginning of the end of the huge waste under FISMA and the start of an era of continuous monitoring and automation. Long overdue. Look for news stories over the coming days.
Alan”

Like I say sometimes, I’m a bear of little brain and a recovering infantryman, but why is the answer to a law to make another law saying the same exactly the same thing.  All I have to say is this:  You’re not on Slashdot, you actually have to read the bill before you comment on it.  I didn’t see anything that supports what Alan’s saying.    =)

Capitol at Sunset by vgm8383.

To me, the very interesting thing about this bill is this provision:

“Before entering into or renewing a covered contract, the Secretary, acting through the Chief Information Officer, must determine that the contractor has an internal information systems security policy that complies with the Department’s information security requirements, including with regard to authentication, access control, risk management, intrusion detection and prevention, incident response, risk assessment, and remote access, and any other policies that the Secretary considers necessary to ensure the security of the Department’s information infrastructure.”

I have an issue with the language of this provision.  It’s one of scope.

But perhaps an explanation is in order.  Most (OK, mabye half or a little bit more, this isn’t a scientific number) government IT systems are contractor-operated.  These contractors have “Government data” on their corporate networks.  Some of this is fairly benign:  contracting collateral, statements of work, staffing plan, bill rates, etc.  Some of this is really bad:  PII, Privacy Act data, mission data, etc.  Some of this is “gray area”: trouble tickets, event data, SIEM data, etc.

Now taking this back to cost-effective, adequate security, what the Langevin bill means is that you’re taking the FISMA framework and applying it to all contractors without any bounds on what you consider within your realm of protection–ie, according to the language of the bill, if I’m any contractor supporting DHS in an outsourcing engagement, you can audit my network, whether or not it has Government data on it.  This is a problem because your oversight cuts into my margins and in some cases does not provide the Government with the desired level of security.

My response as a contractor is the following:

• Increase my rates to compensate for the cost of demonstrating compliance
• Do not bid DHS contracts
• Adopt a policy that says that DHS policies apply to the systems containing government mission data and meta-data
• Charge the Government at Time and Materials for any new requirements that they levy on you for mitigation

Unfortunately, this is a game that the Government will win at with respect to controlling the contractor’s network and lose at with respect to cost.

Good contractors understand the liability of having separation between Government data and their own network.  Back in my CISO role, that was the #1 rule–do not putGovernment data on the corporate network or “cross the streams” (Thanks, Vlad).  In fact, I wrote a whole chunk of blog posts last year about outsourcing, go check them out.  In fact, we would give to the customer anything that could be built in a dedicated mode specifically for them.  The dedicated network sections used the customer’s policy, procedures, standards, and they got to test them whenever they wanted.  In back of that was a shared piece for things that needed large economy of scale, like the STK 8500 and the NOC dashboards to put all the performance data on one screen.

Having said that, some data does need to cross over to the contractor’s network (or, even better, a separate management network) in order to provide economy of scale.  In our case, it was trouble tickets–in order to split field technicians across different contracts to keep them billable, the only cost-effective way to do this is to have tickets go into a shared system.  Any other solution costs the Government a ton of money because they would be paying for full-time field techs to be on-site doing nothing.

The problem is that our guidance on contractor systems is grossly outdated and highly naive.  The big book of rules that we are using for contractor security is NISPOM.  Unfortunately, NISPOM only applies to classified data, and we’re left with a huge gap when it comes to unclassified data.

What we need is the unclassified version of NISPOM.

The NIST answer is in section 2.4 of SP 800-53:

The assurance or confidence that the risk to the organization’s operations, assets, and individuals is at an acceptable level depends on the trust that the authorizing official places in the external service provider. In some cases, the level of trust is based on the amount of direct control the authorizing official is able to exert on the external service provider with regard to the employment of appropriate security controls necessary for the protection of the service and the evidence brought forth as to the effectiveness of those controls. The level of control is usually established by the terms and conditions of the contract or service-level agreement with the external service provider and can range from extensive (e.g., negotiating a contract or agreement that specifies detailed security control requirements for the provider) to very limited (e.g., using a contract or service-level agreement to obtain commodity services such as commercial telecommunications services).

Hmmm, in a classic ploy of stealing lines from my Guerilla CISO Bag-o-Tricks ™, NIST has said “Well, it depends”.  And yes, it depends, but how do you impement that when OMB dictates that what NIST says is THE standard?

• When the Feds Come Calling
• How to Not Let FISMA Become a Paperwork Exercise
• More on Georgia’s FISMA Reporting
• Comments on SCAP 2008
• Random Thoughts on “The FISMA Challenge” in eHealthcare

Dear <enter candidate’s name>,

Congratulations on your inauguration as the President of the United States. This is a huge accomplishment in your career.

I am writing this letter to tell you that you are inheriting a phenomenal opportunity to succeed where it comes to IT security in the Government. Your predecessors have buit a very viable framework for IT security in the US Federal Government. Arrayed around you are some of the brightest and the best people who have done extraordinary work in increasing the cyber security of the United States Government. The following people are included in their ranks:

• Ron Ross and Marianne Swanson and the rest of the staff in the NIST FISMA project who have labored long and hard to provide research, standards, and guidance not just to the Federal Government but to the nation and the rest of the world.
• Karen Evans and the rest of the staff at OMB who have set the policy that the executive branch has followed. They are not afraid to make decisions in the face of adversity.
• US-CERT and the Department of Homeland Security have made huge strides towards building a Government-wide monitoring system. Considering that they started “from scratch” 5 years ago, this is a non-trivial accomplishment.
• The people at DISA and NSA who have developed technical guidance before it was popular to do so–before FISMA, before PPD-63.

These and countless other people have “fought the good fight” in bringing IT security to the masses in such a scale that is unprecedented before in history.

But from where I, a humble servant of the public, stand, there are 2 things that you and your administration can do as a whole to increase our Government’s IT security.

#1 Please appoint an executive-branch Chief Information Officer (CIO) and a Chief Information Security Officer (CISO) with both the responsibility and the authority to secure the executive branch’s IT systems. The reason I ask for this is that the Federal Government’s IT infrastructure is a federation of individual business units that are managed separately for risk. At each level of Government, there is an IT manager and a security person to support them–all the way up the chain of command–except for at the top where there is a void wanting to be filled.

As has often been said, the answer to bureaucracy is not to throw more bureaucracy at it, and so creating new positions is not something to do lightly. What our nation needs is a pair of true technology managers at the executive branch level who can adequately manage risk instead of compliance.  This is a tremendous need for the executive branch: OMB is focused on compliance and fiscal responsibility and compliance, NIST is focused on research and developer outreach, US-CERT is focused on highly tactical IT security operations, and no one entity controls the strategic security direction of the nation.

#2 Please learn how to use the economic might of the Federal Government to allow the market to determine winners in the security space. What I mean by this is that the Government has for too long put up with inferior IT products and services because we do not present a unified front to the vendors.

Our Federal IT budget for this year is ~$75B and this is a huge force to bear on the market. This means that the Government is in a prime position to get whatever they ask for from the technology industry, all you have to do is use your fiscal power in a coordinated manner.

Once again, congratulations on the new job.

Cheers

–Rybolov

White House with a Tilt Shift by Michael Baird

• It’s a Problem of Scale!
• No, FISMA Doesn’t Require That, Silly Product Pushers
• William Jackson on FISMA: It Works, Maybe
• GAO’s 5 Steps to “Fix” FISMA
• Some Comments on SP 800-39

Maybe I’ve been working on slide decks for too long.  That’s why I haven’t been blogging much over the past week:  when you spend 8 hours a day revising and formatting slides, your brain turns to jello.

Then suddenly on Tuesday, it hit me:  the Government’s problem with security is one of scale.  And at this point you all go “Duh, where have you been for the past 200 years?”  And yes, it’s not a problem exclusive to security, it goes hand-in-hand with personnel management, financial management, $foo management, and $bar management

Large-Scale Scaley Carp Photo by radcarper

Now the scale in itself isn’t really the problem, it’s that we don’t have information security models that scale to that level.  And what I mean by that is that each agency is pretty much their own enterprise.  The entire executive branch is one huge federation of independent enterprises (and some of the enterprises are federated, but we’ll ignore that for the time being).  Most of our existing thoughts on information security management are focused on the enterprise, and the only hope to use them is to manage each enterprise separately.

Really, folks, we don’t have information security models that scale up as massively as we need to, and what we’ve been doing is borrowing from other fields, most notably Federal law and public accounting.  Unfortunately for us, these are models based on compliance, not risk management.  Even then, I don’t see the compliance angle going away anytime soon.

Now this is the really big problem:  everybody has some kind of criticism about how the Government runs their information security.  But I don’t see anybody with a viable alternative, nor do I expect to see one because the only people with problems on this scale are large governments.

• Now ISC2 Blogs have an Opinion on FISMA
• Federated Vulnerability Management
• An Open Letter to the Next President of the United States
• NIST’S FISMA Pase II–Who Certifies Those who Certify the Certifiers?
• Massively Scaled Security Solutions for Massively Scaled IT

I spent the last couple of weeks working on a proposal. It was the best of times, it was the worst of times. Hell, I don’t even know if the thing will even get read this year.

Anyway, on to the rants, that’s why you’re all here anyway. =)

#1 Don’t sell methodology. As a customer receiving a proposal, what I think when I get your methodology is that you don’t know my pain points enough to know how you can help me, so you give me a generic, templated proposal. As a contractor making the proposal, when I see that our proposal doesn’t have any real content, I wonder if we know the customer enough to actually pitch and win a deal.

#2 Small proposals are better as long as they’re relevant and answer what the RFP calls for. Don’t be afraid to chop out boilerplate-esque sections of the proposal.

#3 The Government wants way too much stuff in a proposal. It makes life refreshing and tasty when you cycle yourself back out into the private sector.

#4 Rybolov’s simple proposal format, blatantly lifted from the military:

• Situation and Mission: what problem does the Client have? Demonstrate that you understand what they’re asking for.
• Execution: This is what we’re trying to make the solution.  More here is better as long as it avoids being “fluffy”.
• Service and Support: Assumptions, what we need to do the job.
• Command and Control: What our management plan is, who our people are, and what our qualifications are.

• What the Government Looks for in a Product
• Some Words on Steinnon
• How I Do the “FISMA Thang”
• HR 5983–DHS Now Responsible for Contractor Security
• A Funny Thing Happened Last Week on Capital Hill