Let’s talk process flow rants here for a second.

Every couple of weeks, OMB issues a new memorandum setting policy for the executive branch.  They release the memo to the agency heads who then respond–a policy-based syn/ack/fin loop if you will.

All the memos are set up on the OMB website at this url.

Notice something missing?  Where is the RSS feed?  Seriously, if you want somebody other than just the agency heads to be informed of all your newest issues, you need to make it subscribable either via email or RSS feed.  There are tons of people who would subscribe, and it makes your job that much easier.

This rant was brought to you by the letters R and S.  =)

• An Open Letter to the Next President of the United States
• Federated Vulnerability Management
• HR 5983–DHS Now Responsible for Contractor Security
• How to Not Let FISMA Become a Paperwork Exercise
• “Machines Don’t Cause Risk, People Do!”

No big surprise by now, I work for an accounting firm.  Oh, what’s that?  Oh yes, that’s right, it’s a consulting firm with a high percentage of accountants, including a plethora of CPAs.  “Accounting firm” is so 1950s-ish. =)

It’s my secret theory (well, not so much of a secret now, just between the Internet and me) that the primary problem we have in information security is that as a field we have borrowed heavily from public accounting.  The only problem is that public accounting is different from what we do.

Goals for public accounting run something like this:

• Eliminate fraud through oversight
• Protect the company’s money from rogue agents
• Protect the shareholders of public companies
• Ensure accountability of actions

Accounting for Non-Accountants photo by happyeclair.

As a result of their goals, accountants have an interesting set of values:

• Signatures are sacred
• Separation of duties is sacrosanct
• Auditing is designed to act as a deterrent to fraud
• “Professional Skepticism” is a much-valued trait
• Zero-Defects is a good condition

In other words, accountants live in a panopticon of tranparency, the concept being that through oversight and transparency, people will not become evildoers and those that do will be caught.  Pretty simple idea, makes me think about IDS in an entirely new light.

Words that accountants use that mean something entirely different from the way you or I use them:

• Fraud, Waste, and Abuse: They’re talking about spending money, I’m usually talking about people doing something ethically wrong.
• Investigation: They’re looking at the numbers to see how a particular number was created.  Me, I bring the nice people with guns when I do an investigation.
• Incident: Their version is what I would call an event.  When I call something an incident, we’re headed towards an investigation.
• Security test and evaluation: To them, it’s a compliance audit.  To me, it’s determining the frequency that the system will fail and if we have a way to fix it once it does.  Remember this, it’s a critical difference.
• Control: I think their version has something to do with having oversight and separation of duties.  Me, when I see this word, I think “countermeasure to a specific threat and vulnerability”.
• Audit: An activity designed to prove that fraud has not happened.  Usually we don’t use the word unless we absolutely have to.
• Technical: They’re talking about the highly-detailed accounting rules.  I’m talking about if you know how to build your own server and OS using lumps of raw silicon and a soldering iron.
• Checklist: They’re talking about a sacred list that condenses all the rules into an easily-auditable format.  Me, I’m thinking that a checklist is something that will fail because my threats and their capabilities don’t fit into nice little lists.
• Forensics: Their version is what I would call “research to find out where the money went to” and involves looking at a bunch of numbers.  My version has something to do with logs, memory dumps, and hard drive images.
• Risk Management: This has something to do with higher interest rates for high-risk loans.  For me, it’s looking for countermeasures and knowing what things to skimp on even though the catalog of controls says you have to have it.

In short, pretty much anything they could say about our line of work has a different meaning.  This is why I believe it’s a problem if we adopt too much of their methodology and management models because they are doing similar activities to what security people do, only for different purposes.

In order to understand the mentality that we’re working with, let’s give you a couple of scenarios:

After-Work Optional Training Session: The accountants not only make you put your name on the attendance roster but you have to sign it as well.  Are they worried that you’re committing fraud by showing up at training that you were not supposed to, so they need some sort of signature nonrepudiation to prove that you were there?  No!  They just make you sign it because they believe in the power of the signature and that’s just how they do things, no matter how trivial.

The Role of Security: To an accountant, the role of security in an organization is to reduce fraud by “hack-proof” configurations and monitoring.  This is a problem in that since security is economics, we’re somehow subordinate to the finance people.

Let’s look at the world of the typical security practitioner:

• The guidance that security professionals have is very contradictory, missing, or non-relevant.
• Really what we do comes down to risk management, which means that sometimes it makes more sense to break the rules (even though there is a rule that says break the rules, which should freak your brain out by now if you’re an accountant).
• We have a constantly changing environment that rules cannot keep up with.

Now this whole blog post, although rambling on about accountants, is aimed at getting a message across.  In the US Federal Government, we use a process called certification and accreditation (C&A).  The certification part is pretty easy to understand–it’s like compliance, do you have it and does it work.  CPAs will readily understand that as a controls assessment.  That’s very much a transferable concept.

But in accreditation, you give the risks to a senior manager/executive and they accept the risks associated with operating the system.  The CPA’s zero-defects world comes through and they lie on the ground doing the cockroach.  Their skills aren’t transferable when dealing with risk management, only compliance with a set of rules.

Once again, the problem with security in Government is that it’s cultural.

And don’t get me wrong, I like accountants and they do what I do not have neither the skills nor the desire to do.  I just think that there aren’t as many transferable skills between our jobs as there might seem on the surface.

• White Professional Male Turned CISSP Seeks Mega-Sized Security Management Model
• An Open Letter to NIST About SP 800-30
• How to Not Let FISMA Become a Paperwork Exercise
• Security Assessment Economics
• Split-Horizon Assessments and the Oversight Effect

Any comment or graffiti you want to put up in the comments, go ahead.  Only stipulation is that it’s profanity-free (ack, this coming from me?) and relevant to security in the Federal Government.

Why do this?  Well, to give a voice to those who don’t say anything about what’s going on.  We need to hear more from the “silent infosec majority” who just do their jobs every day.

• Some Thoughts on Comments to My Blog…
• On Government Employees, Culture, and Survivability
• The Press has Me all Confused
• The World Asks: is S.773 Censorship?
• Entrepreneurship and Government 2.0

This article at SC Magazine is exactly why.  Kudos to Dan Philpott for calling the author on his errors.

Things that go through my mind about articles like this:

• Is it that slow of a news day?  FISMA stuff is always good for a couple yucks when there’s nothing else to talk about.  Looks like somebody needed filler while everybody was flying to Black Hat and DefCon.
• Once again, we’re confusing FISMA the law with the implementation thereof.  Yawn.
• Ack, somebody who likes FDCC.  Actually, I like it too in theory, I just don’t like the implementation.
• “Government has influence when it comes to awareness and will have opportunities to use it.”  Um, yes, it’s the $75B IT budget, flex that muscle wherever you want to get the secure products you want.  Do not underestimate the power of the budget.
• Follow the FISMA Naysayer and spot somebody who’s looking for money.  In this case, it’s Fortify.

Funny thing is that I think I met the guy from Fortify a couple of months ago at a NoVa OWASP meeting for a showing of their fun-but-FUDtastic movie about application security.  You know, you’ve seen the trailer, it looked like this:

There is a way to influence thinking in this town, and writing trash articles like this is not the way to do it.  If Fortify really wants to change the world, I have some ideas on how to do it, but nobody ever asks.  =)

FUD Truck Makes a Delivery photo by crmudgen23.

Guerilla CISO story time:

About 9 months ago, I got a marketing packet from Borderware.  It said that “FooCorp is identified as sending spam” and offered me the opportunity to join their reputation service.

Looking at the materials they sent me, I deduced that none of the source IPs they listed was in our netblock and that what they were referring to was spam using @foocorp.com email addresses as the “from” address.  Um, not a whole lot you can do to stop that, although it does make for some fun abuse@ emails from users who don’t understand how spam works:  “Quit sending me this stuff, I’ll burn down your data center myself!!!111oneoneone”

Anyway, since the whole packet was pure FUD and not really relevant to anything I wanted to do, I sat down and sent an email to their Director of Marketing and CTO:

I know Borderware’s products, we use them in some of our solutions, and you have a good reputation.  Please don’t resort to such a lowbrow marketing scheme because it sullies your brand.

I think Fortify is in the same boat.  They have a good reputation–I have a friend who works for one of their biggest customers, and if he’s cool with it, I am.

But the question for all security companies remains:  how do I sell my product without resorting to spreading FUD everywhere I go?

• More Vendor Craziness
• No, FISMA Doesn’t Require That, Silly Product Pushers
• Comments on SCAP 2008
• Let’s Face it, Half the Security Industry is a Pyramid Scheme
• Splunk Goes After the FISMA Lucre, They’re not Alone

A couple of months before I was activated and went to Afghanistan, I got a briefing from a Special Forces NCO who had done multiple tours in the desert.  One thing he said still sticks in my mind (obviously paraphrased):

“The Afghanis, they live in mud huts, they don’t have electricity, they are stick-people weighing 85 lbs, and to say that we could bomb them into the stone age would be an advancement in their technology level.  But never underestimate these people, they’re survivors.  They’ve survived 35 years of warfare, starting with the Soviets, then they fought a civil war before we arrived on the scene.  Never underestimate their ability to survive, and have respect for them because of who they are.”

Today, I feel the same way about government employees, even more so because it’s an election year:  they’re survivors.

Now time for what I see is the “real” reason why the government is doing badly (if that’s what you believe–opinions differ) at security: it’s all an issue of culture. I have a friend who converted a year ago to a GS-scale employee and took a class on what motivates government employees. Some of these are obvious:

• Pride at making a difference
• Helping people
• Supporting a cause
• Gaining unique experience on a global-class scope
• Job stability
• Retirement benefits

And one thing is noticeably absent: better pay and personal recognition.  Hey, sounds like me in the army.

The Companion Family Plan for Survival at Home photo by Uh … Bob.

Now I’m not trying to stereotype, but you need to know the organizational behavior pieces to understand how government security works. And in this case, the typical government employee is about as survival-aware as their Afghani counterpart.

Best advice I ever heard from a public policy wonk: the key to survival in this town is to influence everything you can get your hands on and never have your name actually written on anything.

In other words, don’t criticize, be nice to everybody even though you think they are a jerk, and avoid saying anything at all because you never know when it will be contrary to the political scene.  The Government culture is a silent culture. That’s why every day amazing things happen to promote security in the Government and you’ll never hear about it on the outside.

One of the reasons that I started blogging was to counter the naysayers who say that FISMA is failing and that the Government would succeed if they would just buy their product for technical policy compliance or end-to-end encryption.  Sadly, the true heroes in Government, the people who just do their job every day and try to survive a hostile political environment, are giving credit to the critics because of their silence.

Which brings me to my point:

Yes, my name is Rybolov and I’m a heretic, but this is the secret to security in the Government:  it’s cultural at all layers of the personnel stack.  Security (and innovation, now that I think about it) needs a culture of openness where it’s allowable to make mistakes and/or criticize.  Doesn’t sound like any government–local, state, or federal–that I’ve ever seen.  However, if you fix the culture, you fix the security.

• Some Thoughts on Comments to My Blog…
• Learning GovieSpeak: The Plum Book
• Cloud Computing and the Government
• In Which Our Protagonist Discovers We Need More Good Public Policy People Who Understand Security
• Auditors, Frameworks, and Philosophy

You were thinking this was part of the rainbow series, along with the orange book, the red book, and the fuchsia book, weren’t you?

Well, no, security dweebs, we’re on a public policy kick, probably will be until the end of the year (more on that to follow, stay tuned), so you wouldn’t be so lucky.

The Plum Book’s official title is Government Policy and Supporting Positions and basically it’s a huge staffing chart for the Senior Executive Service–the political appointees.  Congress publishes the Plum Book after each presidential election, so for those of us who remember our civics lessons in high school, that would be every 4 years, and the last one was published in 2004.

In fact, you can see the last edition here.  Caveat:  it’s dry, like the uber-trocken Franken white wine that grows in the fields around where I used to live in Germany–so dry that it sucks the moisture right out of you.

Plum Pickin photo by Secret Tenerife

Now why do we care about the Plum Book?  Well, that’s a good question.  Have a look at some of the staffing plans in the plum book, and you’ll see something missing:  Agency CISOs.

Now, I’m not a rocket scientist on org charts, but it seems to me that unless you put CISOs up to where they’re answerable to the agency head, they’re just a cost center inside the IT department with no visibility to the decision-makers.  Once again, we’ve crippled our security staffs like the old-school way of doing things.

On another note, taking a quick straw poll of the agency CISOs that I know, I think about half of them are political appointees, and half of them are GS-15s.  So what’s the difference?

Well, political appointees (SES) are appointed by the President.  They make a better target because they have much more visibility from the higher-ups they are more political in nature.

GS-scale employees are civil service careerists.  Usually these are the guys who have moved up the ranks in the various agencies and know quite a bit of things.

Which is better?  Well, if you want survivability, then GS-scale is the way to go.  If you want to make the most difference, SES is the ticket.

Most of us will never get the choice. =)

• On Government Employees, Culture, and Survivability
• It’s a Problem of Scale!
• Now ISC2 Blogs have an Opinion on FISMA
• Why We Need PCI-DSS to Survive
• Split-Horizon Assessments and the Oversight Effect