Lamenting the Seppuku of the NinjaCISO

Posted February 25th, 2009 by

At the beginning of the year, I was absolutely tickled pink: I almost had a copycat.

The NinjaCISO blog was started shortly after the new year and seemed interesting in what they had to say over the next couple of months.  I eagerly waited for their every post, wondering what kind of insight the Ninja would come up with next.  Since for the most part we operate in unchartered waters here at the Guerilla-CISO, it sometimes is nice to get different points of view so we don’t feel like we’re some kind of bizarre Government information security self-licking ice cream cone.

Then in mid-February, the whole blog was replaced with a cartoon saying that “On the Internet, nobody knows that you’re a dog”.  This can mean only one thing:  the Ninja was given a cease-and-desist by their chain of command and was forced to commit blog seppuku.  And the blogging world experienced a small void.

Nobody Knows You’re a Dog lifted from NinjaCISO.com.

See, dear readers, this is a problem for Government employees who blog.  Let’s look at a little bit more extreme example: military bloggers (milblogs).

You see, the military has gone back and forth on this a couple of times.  In April 2007, the Army decided that soldiers shouldn’t blog without notifying their commander, (clarified here) and the Global War Against Blogs was started, much to the dismay of a lot of clueful people who understand the value that blogs bring to the DoD.

Yes, Joe is dumb.  Joe talks about stuff that he shouldn’t really talk about.  But Joe can also talk about the village in Afghanistan where he’s a local hero because he rescued a policeman while he was being held hostage.  Joe can also talk about the school that the Taliban burned and how US money and some “local matching funds” from the Provincial Governor brought carpets, pens, and pads of paper so that the kids could continue to learn how to read and write.

And this is the conundrum: in a war where the “bad guys” are winning the media war, how do you give a voice to the guys doing good things but just enough so that they don’t talk about anything that you don’t want them to–troop movements, physical security problems, and how they really feel about the administration’s policies?

And so back to my real message here:  we as an industry need to hear from the invisible people who make information security in the Government work.  Otherwise, you would think that FISMA is failing, Government CISOs are a bunch of buffoons who don’t know how to get a good report card, DHS is monitoring the Interwebs looking for the next Nick Haflinger, and the only people getting any benefit out of the way we do information security is a bunch of fat-cat contractors and their shareholders. (Side note, how do I sign on for this contractor wealth thing?  I must be doing it all wrong.)

We now have an administration that talks about openness, transparent democracy, and all this Government 2.0 stuff.  Truth be told, I don’t think anybody has thought about extending that transparency to trickle down to the “worker-bees”.  These are really 2 different issues: official blogs v/s personal blogs that might be career-related.  I think we have a pretty good handle on the official blogs, but there is a huge void of policy in the realm of personal blogs.

Message to the administration: what we want and need is a blog policy for Government employees that works like this:

  • Don’t use your title or agency in anything you write
  • Don’t use Government IT resources (desktops, servers, or network) to blog
  • Don’t blog at work on the clock as a Government employee
  • Do use a pseudonym if at all possible
  • Do not violate the Hatch Act with your blog
  • Do try to blog objectively about policy issues
  • Do talk about your successes
  • Do encourage others to make the Government the best that it can be
  • Do offer suggestions to problems

As for the NinjaCISO’s content, you can catch bits and pieces of it here on Technorati.

Orwell’s Reporter Lady Goldstein photo by Boris from Vienna.  For clarification, we’re not talking 1984-type things here folks, this is just the blagosphere.  However, it is a funny picture.



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The 10 CAG-egorically Wrong Ways to Introduce Standards

Posted February 20th, 2009 by

The Consensus Audit Guidelines (CAG) appear, at this point, to be a reasonable set of guidelines for mediating some human threats. I’m looking forward to seeing what CAG offers and have no doubt there will be worthwhile and actionable controls in the document. That said, there are significant reasons approach CAG with skepticism and assess it critically.

The motivation for CAG is described in a set of slides at the Gilligan Group site. It starts with a focus on what CIO’s fear most: attacks, reduced operational capability, public criticism, data loss, etc. Then it rightly questions whether FISMA is adequately addressing those problems. It doesn’t and this is the genesis of the CAG.

Consensus photo by Eirik Newth.

Unfortunately CAG subsequently develops by pairing this first valid premise with a set of false premises.  These propositions are drawn from slides at gilligangroupinc.com, attributed to John Gilligan or Alan Paller:

  1. All that matters are attacks. The central tenet of Bush’s Comprehensive National Cyber Initiative (CNCI) is adopted as the CAG theme: “Defense Must Be Informed by the Offense”. CAG envisions security as defense against penetration attacks. As any seasoned security practitioner knows, attacks are a limited subset of the threats to confidentiality, integrity and availability that information and information systems face.
  2. Security through obscurity. CAG seems to have taken the unspoken CNCI theme to heart too, “The most effective security is not exposed to public criticism.” Since its very public December 11th announcement no drafts have been made publicly available for comment.
  3. False dichotomy. CAG has been promoted as an alternative to the OMB/NIST approach to FISMA. It isn’t. An alternative would target a fuller range of threats to information and information system security. CAG should be considered a complement to NIST guidance, an addendum of security controls focused on defense against penetration by hackers. NIST has even acted on this approach by including some CAG controls into the 800-53 Rev. 3 catalog of controls.
  4. There is too much NIST guidance! This is the implication of one CAG slide that lists 1200 pages of guidance, 15 FIPS docs and the assorted Special Publications not related to FISMA as detriments to security. It’s like complaining that Wikipedia has too many articles to contribute to improved learning. Speaking as someone who scrambled to secure Federal systems before FISMA and NIST’s extensive guidance, having that documentation greatly improves my ability to efficiently and effectively secure systems.
  5. NIST guidance doesn’t tell me how to secure my systems! NIST’s FISMA guidance doesn’t step you through securing your SQL Server. The Chairman of the Joint Chiefs also doesn’t deliver your milk. Why not? It’s not their job. NIST’s FISMA guidance helps you to assess the risks to the system, decide how to secure it, secure it accordingly, check that a minimum of controls are in place and then accept responsibility for operating the system. NIST also provides documents, checklists, repositories, standards, working groups and validation of automated tools that help with the actual security implementation.
  6. Automated security controls negate human errors. With the premise of all threats being attacks this is nearly a plausible premise. But not all security is technical. Not all threats come from the Internet. DHS, NIST, Mitre, and their partners have pursued automated security controls to enforce and audit security controls for years but automated security controls can only go so far. Human errors, glitches, unexpected conflicts and operational requirements will always factor into the implementation of security.
  7. Audit compatibility as a hallmark of good security. There is a conflict of focus at the heart of the CAG, it seeks to both improve its subset of security and improve audit compatibility. For technical controls this is somewhat achievable using automation, something NIST has pursued for years with government and industry partners. For operational and management controls it results in audit checklists. But audits are fundamentally concerned with testing the particular and repeatable, security needs focus on evaluating the whole to ensure the necessary security results. An audit sees if antivirus software is installed, an evaluation sees if the antivirus software is effective.
  8. Metrics, but only these metrics over here. When selecting the current crop of CAG controls decisions on what to include were reportedly based on metrics of the highest threats. Great idea, a quantitative approach often discovers counter-intuitive facts. Only the metrics were cherry picked. Instead of looking at all realized threats or real threat impacts only a count of common penetration attacks were considered.
  9. With a sample of 1. As a basis for determining what security should focus on the whole breadth of the security profession was queried, so long as they were penetration testers. Yes, penetration testers are some very smart and talented people but penetration testing is to security what HUMINT is to intelligence services. Important players, expert practitioners but limited in scope and best used in conjunction with other intelligence assets.
  10. Assessments rely on paper artifacts. The NIST guidance does not require paper artifacts. The first line in the NIST SP 800-53A preface is, “Security control assessments are not about checklists, simple pass-fail results, or generating paperwork to pass inspections or audits-rather, security controls assessments are the principal vehicle used to verify that the implementers and operators of information systems are meeting their stated security goals and objectives.” NIST SP 800-37 specifically and repeatedly states, “Security accreditation packages can be submitted in either paper or electronic format.”

CAG is a missed opportunity. Of the myriad problems with our current FISMA regime a lot of good could be achieved. The problems with guidance have many causes but can be addressed through cooperative development of best practices outside of NIST. The Assessment Cases for SP 800-53A is an example of how cooperative development can achieve great results and provide clear guidance. Other problems exist and can be addressed with better training and community developments.

My hope is that the Consensus Audit Guidelines will move towards a more open, collaborative development environment. The first release is sure to deliver useful security controls against penetration attacks. As with all good security practices it will likely need to go through a few iterations and lots of critical assessment to mature. An open environment would help foster a more complete consensus.

Consensus photo by mugley.



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Beware the Cyber-Katrina!

Posted February 19th, 2009 by

Scenario: American Internet connections are attacked.  In the resulting chaos, the Government fails to respond at all, primarily because of infighting over jurisdiction issues between responders.  Mass hysteria ensues–40 years of darkness, cats sleeping with dogs kind of stuff.

Sounds similar to New Orleans after Hurricane Katrina?  Well, this now has a name: Cyber-Katrina.

At least, this is what Paul Kurtz talked about this week at Black Hat DC.  Now I understand what Kurtz is saying:  that we need to figure out the national-level response while we have time so that when it happens we won’t be frozen with bureaucratic paralysis.  Yes, it works for me, I’ve been saying it ever since I thought I was somebody important last year.  =)

But Paul…. don’t say you want to create a new Cyber-FEMA for the Internet.  That’s where the metaphor you’re using failed–if you carry it too far, what you’re saying is that you want to make a Government organization that will eventually fail when the nation needs it the most.  Saying you want a Cyber-FEMA is just an ugly thing to say after you think about it too long.

What Kurtz really meant to say is that we don’t have a national-level CERT that coordinates between the major players–DoD, DoJ, DHS, state and local governments, and the private sector for large-scale incident response.  What’s Kurtz is really saying if you read between the lines is that US-CERT needs to be a national-level CERT and needs funding, training, people, and connections to do this mission.  In order to fulfill what the administration wants, needs, and is almost promising to the public through their management agenda, US-CERT has to get real big, real fast.

But the trick is, how do you explain this concept to somebody who doesn’t have either the security understanding or the national policy experience to understand the issue?  You resort back to Cyber-Katrina and maybe bank on a little FUD in the process.  Then the press gets all crazy on it–like breaking SSL means Cyber-Katrina Real Soon Now.

Now for those of you who will never be a candidate for Obama’s Cybersecurity Czar job, let me break this down for you big-bird stylie.  Right now there are 3 major candidates vying to get the job.  Since there is no official recommendation (and there probably won’t be until April when the 60 days to develop a strategy is over), the 3 candidates are making their move to prove that they’re the right person to pick.  Think of it as their mini-platforms, just look out for when they start talking about themselves in the 3rd person.

FEMA Disaster Relief photo by Infrogmation. Could a Cyber-FEMA coordinate incident response for a Cyber-Katrina?

And in other news, I3P (with ties to Dartmouth) has issued their National Cyber Security Research and Development Challenges document which um… hashes over the same stuff we’ve seen from the National Strategy to Secure Cyberspace, the Systems and Technology Research and Design Plan, the CSIS Recommendations, and the Obama Agenda.  Only the I3P report has all this weird psychologically-oriented mumbo-jumbo that when I read it my eyes glazed over.

Guys, I’ve said this so many times I feel like a complete cynic: talk is cheap, security isn’t.  It seems like everybody has a plan but nobody’s willing to step up and fix the problem.  Not only that, but they’re taking each others recommendations, throwing them in a blender, and reissuing their own.  Wake me up when somebody actually does something.

It leads me to believe that, once again, those who talk don’t know, and those who know don’t talk.

Therefore, here’s the BSOFH’s guide to protecting the nation from Cyber-Katrina:

  • Designate a Cybersecurity Czar
  • Equip the Cybersecurity Czar with an $100B/year budget
  • Nationalize Microsoft, Cisco, and one of the major all-in-one security companies (Symantec)
  • Integrate all the IT assets you now own and force them to write good software
  • Public execution of any developer who uses strcpy() because who knows what other stupid stuff they’ll do
  • Require code review and vulnerability assessments for any IT product that is sold on the market
  • Regulate all IT installations to follow Government-approved hardening guides
  • Use US-CERT to monitor the military-industrial complex
  • ?????
  • Live in a secure Cyber-World

But hey, that’s not the American way–we’re not socialists, damnit! (well, except for mortgage companies and banks and automakers and um yeah….)  So far all the plans have called for cooperation with the public sector, and that’s worked out just smashingly because of an industry-wide conflict of interest–writing junk software means that you can sell for upgrades or new products later.

I think the problem is fixable, but I predict these are the conditions for it to happen:

  • Massive failure of some infrastructure component due to IT security issues
  • Massive ownage of Government IT systems that actually gets publicized
  • Deaths caused by massive IT Security fail
  • Osama Bin Laden starts writing exploit code
  • Citizen outrage to the point where my grandmother writes a letter to the President

Until then, security issues will be always be a second-fiddle to wars, the economy, presidential impeachments, and a host of a bazillion other things.  Because of this, security conditions will get much, much worse before they get better.

And then the cynic in me can’t help but think that, deep down inside, what the nation needs is precisely an IT Security Fail along the lines of 9-11/Katrina/Pearl Harbor/Dien Bien Fu/Task Force Smith.



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Inside the Obama Administration’s Cyber Security Agenda

Posted January 28th, 2009 by

Interesting article in Security Focus on President Obama and cybersecurity.  Yes, I complained on twitter because the “document on homeland security” is not really any kind of a solution, more like a bullet list of goals that sound suspiciously like a warmed-over campaign platform.

Guess what?  Every President does this, they put out their agenda for everyone to see.  With the last administration, it was the 5-point President’s Management Agenda.

Let’s be honest here, as Bubba the Infantryman would say, “There are only a couple of ways to suck an egg, and this egg has been around for a long time.”  Any cybersecurity strategy will harken back to the National Strategy to Secure Cyberspace because the problems are the same.  If you remember back to when the NStSC was first released, a horde of critics appeared out of the woodwork to say that there wasn’t enough implementation details and that the strategy wouldn’t be implemented because of that.  Well, they were partly right.

And now there’s the President stating his agenda with the same ideas that people have been saying for 6 years in more detail than what and suddenly it’s new and innovative.  That’s politics for you, folks.  =)  Bubba, in a rare fit of wisdom would say “The way you can tell the true pioneers is that they have arrows sticking out of their backs” and it might seem apropos here, if maybe a little bit cynical.

Hidden Agenda Eats Agenda photo by emme-dk.

Let’s go through each of the points with a little bit of analysis from myself:

  • Strengthen Federal Leadership on Cyber Security:Declare the cyber infrastructure a strategic asset and establish the position of national cyber advisor who will report directly to the president and will be responsible for coordinating federal agency efforts and development of national cyber policy.

  • Great idea.   Between OMB, NIST, DHS, DoD, DOJ, and a cast of thousands, there is a huge turf war over who really owns security.  Each of these groups do a phenomenal job doing what it is they do, but coordination between them is sometimes more like a semi-anarchist commune than a grand unified effort.  I seem to remember saying at one point that this was needed.  Granted, I was specifically talking about the internal side of the InfoSec Equitites Issue, so the scope here is a little different.

    The Cyber Czar is literally buried deep down inside DHS with no real authority, a presidential advisor like is in the agenda would report directly to the President. 

  • Initiate a Safe Computing R&D Effort and Harden our Nation’s Cyber Infrastructure:Support an initiative to develop next-generation secure computers and networking for national security applications. Work with industry and academia to develop and deploy a new generation of secure hardware and software for our critical cyber infrastructure. 

  • We have a very good R&D plan in place (.pdf caveat), it just needs to be adopted and better funded.  For those of you who need a project, this is like a wishlist on things that some very smart Government guys are willing to fund.

  • Protect the IT Infrastructure That Keeps America’s Economy Safe: Work with the private sector to establish tough new standards for cyber security and physical resilience.

  • Ouch, I cringe when I read this one.  Not that it’s needed because when it really comes down to it, every CISO in the US is dependent on the software and hardware vendors and their service providers.

    Something the world outside the Beltway doesn’t understand is that “standards” are roughly equal to “regulation”.  It’s much, much better if the Government goes to industry groups and says “hey, we want these things to be part of a standard, can you guys work to put it all together?” There might be some regulation that is needed but it should be kept as small as possible.  Where the Government can help is to sponsor some of the standards and work along with industry to help define standards.

    Maybe the best model for this is the age-old “lead the horse to water, demonstrate to the horse how to drink, hold the horses mouth in the water, and you still can’t get them to drink.”  We’ve tried this model for a couple of years, what is needed now is some kind of incentive for the horse to drink and for vendors to secure their hardware, software, firmware, and service offerings.

  • Prevent Corporate Cyber-Espionage: Work with industry to develop the systems necessary to protect our nation’s trade secrets and our research and development. Innovations in software, engineering, pharmaceuticals and other fields are being stolen online from U.S. businesses at an alarming rate.

  • Maybe this gets down to political beliefs, but I don’t think this is the Government’s responsibility to prevent corporate cyber-espionage, nor should you as a company allow the Government to dictate how you harden your desktops or  where you put your IDS.  If you are not smart enough to be in one of these high-tech industries, you should be smart enough to keep your trade secrets from going offshore, or else you’ll die like some weird brand of corporate darwinism.

    Government can prosecute evildoers and coordinate with other countries for enforcement efforts, which is exactly what you would expect their level of involvement to be.

    Yes, in some cases when it’s cyber-espionage directed at the Government by hacking contractors or suppliers (the military-industrial complex), then Government can do something about it with trickle-down standards in contracts, and they usually do.  Think ITAR export controls scoped to a multi-national corporation and you have a pretty good idea of what the future will hold.

  • Develop a Cyber Crime Strategy to Minimize the Opportunities for Criminal Profit: Shut down the mechanisms used to transmit criminal profits by shutting down untraceable Internet payment schemes. Initiate a grant and training program to provide federal, state, and local law enforcement agencies the tools they need to detect and prosecute cyber crime.

  • This point is interesting to me.  We already have rules to flag large transactions or multiple transactions, that’s how Elliot Spitzer got caught.  Untraceable Internet payment schemes sounds like pulp-fiction stuff and income tax tracking to me, I would like to know if they really exist.

    On the other hand, law enforcement does need training.  There really is a shortage of people with the law enforcement and technical security backgrounds who can do investigations.

  • Mandate Standards for Securing Personal Data and Require Companies to Disclose Personal Information Data Breaches: Partner with industry and our citizens to secure personal data stored on government and private systems. Institute a common standard for securing such data across industries and protect the rights of individuals in the information age.

  • National data breach law == good, because it standardizes all of the state laws that are such a hodge-podge you need a full-time staff dedicated to breaking down incidents by jursidiction.  We have something like this proposed, it’s S.459 which just needs to be resurrected and supported by the Executive Branch as part of their agenda.

    A common standard could be good as long as it’s done right (industry standards v/s Government regulation), see my comments above.

     

    Note some key points I want you to take away:

    Nothing is new under the sun.  These problems have been around a long time, they won’t go away in the next 4 years.  We have to build on the work of people who have come before us because we know they’ve looked at the problem and came to the same conclusions we will eventually come to.

    Partnership is emphasized.  This is because as much lip-service we give to the Government solving our problems, the American Way (TM) is for the Government not to be your Internet Nanny.  Government can set the environment to support private information security efforts but it really is up to the individual companies to protect themselves.

    Industry needs to solve its own problems.  If you want the Government to solve the nation’s information security problems, it means that we take US-CERT and have them monitor everything whether you want them to or not.  Yes, that’s where things are heading, folks, and maybe I just spilled the beans on some uber-secret plan that I don’t know about yet.  Trust me, you don’t want the transparency that the Government watching your data would provide.

    Be careful what you ask for.  You just might get it.  When it comes to IT security, be extra careful because you’ll end up with regulation which means more auditors.

    Agenda Grafitti photo by anarchosyn.



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    What’s Missing in the way the Government does Security?

    Posted December 16th, 2008 by

    I love transition time.  We get all sorts of strange people who come in, issue their letters on how they think the Government can solve the major cybersecurity issues for both the Government’s IT systems and for the rest of the US as a whole.  And then, they all leave.

    Nobody actually implements the suggestions because it takes time, effort, and money to get them done, and all that anybody ever wants to give is talk.  Talk is cheap, security is not.

    Many years ago when I became an infantryman, our guest speaker at graduation made one of the most profound statements that I remember over 8 years later: “Infantrymen vote with their feet”. In other words, we’re doers, not talkers, and at one point in our lives we decided that something was important enough to give up 4 years of our lives, maybe more, for this cause.  Even Colonel Davy Crockett after he lost re-election to the House of Representatives wrote “I told the people of my district that I would serve them as faithfully as I had done; but if not … you may all go to hell, and I will go to Texas.”  He died less than 3 years later at the Alamo.  That, ladies and gentlemen, is how you vote with your feet.

    My personal belief is that the primary problem the Government has with security (on both sides of the InfoSec Equities Issue) is that there is a lack of skilled security practitioners upon which to draw from.  If you think about everything we’ve done to date, it’s almost always a way of compensating for our lack of skilled people:

    • Reducing security to a bunch of checklists
    • Providing templates to non-security staff
    • Automation wherever possible
    • “Importing” non-security specialists such as accountants and technical writers in security roles
    • Building a “Franchise Kit” upon which to base a security program
    • Reserving key decisions for trained security staff

    As an industry, we have failed (at least in the public sector) at generating people with the skills to do the job.

    And in light of this, my challenge to you:  have a good idea and think you know how to solve the information security?  Yes, we need those, but what we really need are IT security infantrymen who are willing to be doers instead of talkers.  To answer the title of my blog post, the thing that the Government is missing is you.

    Infantry Action Photo by Army.mil

    So how can you help?  I know moving to DC is a bit of a stretch for most of you to do.  This is a short list of ideas what you can do:

    • Learn how the Government secures systems: don’t just dismiss outright what people in DC are doing because conventional wisdom says that it is failing miserably, and don’t listen to people who do the same.
    • Actively recruitment of techies to “embrace the dark side” and become security people:  We need more technically-savvy security people.
    • Answer the call from DHS when it comes: living in DC is isolating from the rest of the world and all fo the good ideas that are out there.  Maybe you have a phenomenal microstrategy on how to secure IT.  They/we need to know them.  The Government cannot succeed at securing cyberspace (whatever your interpretation of that phrase means) without input from the private sector.
    • Don’t engage the Government only when there’s money in it for you. ~$8B is a ton of money, but if you’re doing your job right as a vendor, you’re solving their problems as a first priority, not a second.
    • Build a better education system for security staff and make better career paths to get people from the technical disciplines into security.


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    In Other News, I’m Saying “Nyet” on S.3474

    Posted December 15th, 2008 by

    It’s probably a shocker to most people, but I’m going to recommend that S.3474 be amended or die on the Senate floor like Caesar.

    I’ve spent many hours reading over S.3474.  I’ve read the press releases and articles about it.  I’ve had some very difficult conversations with my very smart friends.

    I’ve come to the conclusion that S.3474 as written/proposed by Senators Carper and Leiberman is not the answer to information security in the Government as it has been publicized repeatedly, and that anyone who believes the hype is in for a rude surprise next fall if the bill is ratified and signed.

    My thoughts on the matter:

    • S.3474 is not what it is being publicized as.  The people who write the press releases and the articles would have us believe that S.3474 is a rewrite of FISMA 2002 and that it focuses on continuous monitoring of the security of IT systems, both of which are a good thing.  First and foremost, it does not repeal FISMA 2002, and anyone saying that is simply trying to deceive you.  S.3474 adds to the FISMA 2002 requirements and codifies the role and responsibility of the agency CISO.
    • S.3474 does not solve the core problem.  The core problem with security and the Government is that there is a lack of a skilled workforce.  This is a strategic issue that a bill aimed at execution of security programs cannot solve by itself.
    • S.3474 adds to the existing checklists.  People have been talking about how S.3474 will end the days of checklists and auditors.  No, it doesn’t work that way, nor is the bill written to reduce the audits and checklists.  When you introduce new legislation that adds to existing legislation, it means that you have added more items to the existing checklists.  In particular, the provisions pertaining to the CISO’s responsibilities are audit nightmares–for instance, “How do you maintain a network disconnect capability as required by FISMA 2008” opens up a whole Pandora’s Box worth of “audit requirements” which are exactly what’s wrong with the way FISMA 2002 has been implemented.
    • S.3474 puts too much of the responsibilities on the CISO.  It’s backwards thought, people.  The true responsibility for security inside of an agency falls upon that political appointee who is the agency head.  Those are the people who make the decisions to do “unsafe acts”.
    • S.3474 does not solve any problems that need a solution.  Plain and simple, it just enumerates the perceived failings of FISMA 2002.  It’s more like a post-divorce transition lover who is everything that your ex-spouse is not.  Let’s see… technical controls?  Already got them.  Requirements for network monitoring?  Already got them.  2nd party audits?  Already got them.  Requirements for contractors?  Already got them.  Food for thought is that these exist in the form of guidance, does the security community as a whole feel that we need to take these and turn them into law that takes years to get changed to keep up with the pace of technology?  There is some kind of segue there into Ranum talking about how one day we will all work for the lawyers.

    Of course, this is all my opinion and you can feel free to disagree.  In fact, please do, I want to hear your opinion.  But first and foremost, go read the bill.

    i haz a veto pen photo by silas216



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