I’m going to put on my Government Security Heretic Hat for awhile here, bear me out.  By my estimate, half of the security assessments received by the Government have some kind of fraud, waste, and abuse.

What makes me say this is the amount of redundancy in some testing that I’ve seen without any value added.

The way to avoid this redundancy is the concept of common/shared controls.  The whole idea is that you take whatever security controls you have across the board and put them into one bucket.  You test that bucket once and then whenever something  shares controls with that bucket, you look at the shared control bucket and make sure that the assessment is still relevant and accurate.

So, what makes a security assessment not fraud, waste, and abuse?  It’s a good assessment if it does the following:

• Does not repeat a previous assessment.
• Discovers previously-undiscovered vulnerabilities, weaknesses, or findings.
• Has findings that get fed into a risk management plan (accepted, avoided, transferred, etc–think POA&M).
• Is not exhaustive when it doesn’t need to be.
• Provides value to the project team, system owner, and Authorizing Official to make key decisions.

Now the problem is that the typical auditor has a hard time stopping–they have an ethical obligation to investigate anything that their “professional skepticism” tells them is out of place, just like cops have an ethical obligation to investigate anything that they think is a crime.

The Solution?  Don’t use auditors! The public accounting model that we adopted for information security does not scale the way that we need it to for ST&E, and we need to understand this in order to fix security in the Government.

What we need to be doing is Security Test and Evaluation which is focused on risk, not on compliance using a checklist of control objectives.  Usually if you know enough to say “Wow, your patch management process is whacked, you’re at a high risk!” then that’s enough to stop testing patch management controls.  This is one of the beefs I have with 800-53A in the hands of less-than-clueful people:  they will test until exhaustion.

There isn’t a whole lot of difference between ST&E and an audit, just the purpose.  Audits are by nature confrontational because you’re trying to prove that fraud, waste, and abuse hasn’t occured.  ST&E is helping the project team find things that they haven’t thought of before and eventually get the large problems funded and fixed.

The Little Frauds Harrigan & Hart’s Songs & Sketches Photo by Boston Public Library

• How to Not Let FISMA Become a Paperwork Exercise
• Cloud Computing and the Government
• Some Thoughts on POA&M Abuse
• 20 Critical Security Controls: Control-by-Control
• An Open Letter to NIST About SP 800-30

I’ve touched on this about a bazillion times, let me start today with a very simple statement:  due to the scale of the US Government, we cannot find enough skilled security people.

Part of the problem is that good security people need to know the following skills:

• IT technology: since the data more often than not is in a computer, you need to understand them
• People technology: policies and procedures for managing people
• Business sense:  understanding that you’re supporting business goals
• And for Government:  politics

Back when I was PFC Rybolov, my battalion commander told me something along the lines of “The intelligence world is a hard job, you have to be able to out-infantry the infantry, out-mechanic the mechanics, out-radio the radio guys, and you need to know a language.”  Security is pretty much the same thing–you have to out-techie the techies, out-business the MBAs, and out-jerkify the auditors.  =)

Sound complicated?  Yes, it is, and it’s hard to find people who can do all this.  IT is an employment niche, IT security is a niche to a niche.  And there isn’t enough people who have the experience to do it.

So how do we mitigate the staffing shortage?  Here is what we are doing today in the Government:

• CyberCorps scholarship program for undergrads and graduate students with a minimum government service obligation.
• Using other career fields in “crossover roles”–yes, accountants can be used for some light security tasks.  Some things that we think of as security are really Quality Assurance and Change Control jobs that we have a vested interest in making work.
• Using contractors in some roles such as ISSO, ISSM, etc.
• Automation as much as possible.  Technical is easier, the policy and procedures side takes longer.  What you’ll find out eventually is that good IT management is good security management.
• Hanging on methodologies to “automate” the process side of security.

Now this is cool and all, but it’s hard to sustain and really hard to justify as a long-term solution.  In order to support the Government, we need to create more people.  Cybercorps is a start, but the need is so much larger than the supply that we have to consider better ways to create Government security dweebs.

Do we need Security Awareness and Training?  Yes we do, but much more than what is being provided (think system administrator training and procurement specialist training, not end-user training), and as an internal recruiting pipeline.  Still, I don’t think that we can recruit enough people to “the dark side” and that we need to look outside the Beltway for people.  Problem is that DC is such an insular community and we don’t speak the same language as the rest of the world.

• NIST’S FISMA Pase II–Who Certifies Those who Certify the Certifiers?
• A Short History of Cyberwar Lookalikes
• Security Assessments as Fraud, Waste, and Abuse
• Cloud Computing and the Government
• In Response to “Cyber Security Coming to a Boil” Comments….

The Abbot at the Security Monastery takes us through an interesting tour of compliance, risk management, and what the Government is doing.  I’m not biased at all because it’s based on conversations with me or anything like that.  =)

Now for those of you who don’t know me personally, here’s a little bit of trivia for you:  Every week I go back and forth between “wow, we’re doing great things above and beyond what the private sector knows about” and “culturally, security in the Government will never work because you’re trying to do risk management in a zero-defects world”.

• An Open Letter to NIST About SP 800-30
• New SP 800-60 is Out, Categorize Yerselves Mo Better
• It’s a Problem of Scale!
• NIST’S FISMA Pase II–Who Certifies Those who Certify the Certifiers?
• Some Comments on SP 800-39

The perpetual draft document, SP 800-53A, has been officially released after 3 years.  Check out the announcement from NIST here.

Now the interesting thing to me is that NIST is working with some other players (DNI comes to mind) on reference implementations of 800-53A.  This is big, so big that I can’t add enough hyperbole to it.

Why do they need to do reference implementations?  Well, because by itself, SP 800-53A is dangerous if it’s given to people who “don’t get it”.  By that what I mean is this:

• SP 800-53 needs tailoring to distill into actual requirements.
• SP 800-53A needs a huge amount of tailoring to distill into test cases/procedures that match the tailoring that you did with 800-53.
• Taken at face value, 800-53 and 800-53A become the source of “death by compliance”.
• If you think the auditors could grill you to death with 800-53, 800-53A gives them tons more material.

Now time for a war story: I worked on a project where the contractor was having a hard time building a security program, mostly because they didn’t have the right staff to get the job done.  The government told the contractor to use 800-53A as a starting point, and 6 months of insanity followed with 13 “security engineers” in a conference room cranking out documentation that had no basis in reality.  At the end of it all, the contractor handed the Government a bill for $1M.

Now don’t get me wrong, I like the ideas behind 800-53A, but the first thing you need to know when you start using it is when you shouldn’t use it:

• Don’t run test procedures on every computer you have, use an automated tool and do spot-checks to validate that the automated tool works.
• Use less test procedures on low-criticality systems.
• “This procedure is conducted as part of the hardening validation process.”
• Common controls are even more important because you do not want the repetition of effort.

And whatever you do, don’t let 800-53A turn your risk management into a compliance activity.  It has all the potential to do that.

US Government Doc’s photo by Manchester Library.

• OMB Wants a Direct Report
• An Open Letter to NIST About SP 800-30
• Auditors, Frameworks, and Philosophy
• Security Assessments as Fraud, Waste, and Abuse
• Observations on SP 800-37R1

Article from William Jackson in Government Computer News:  Security policies remain a burden to federal IT managers, but they are producing results.

First off, GCN, come into the modern Web 2.0 era by letting people comment on your articles or at least allow trackbacks.  Having said that, let’s look at some of Mr Jackson’s points:

• NIST Special Publications: They’re good.  They’re free.  The only problem is that they’re burying us in them.  And oh yeah, SP 800-53A is finally final.
• Security and Vendors/Contractors:  It’s much harder than you might think.  If there’s interest, I’ll put out some presentations on it in my “copious amounts of free time”.  In the meantime, check out what I’ve said so far about outsourcing.
• Documentation and Paperwork:  Sadly, this is a fact of life for the Government.  The primary problem is the layers of oversight that the system owner and ISSO have.  When you are as heavily audited as the executive branch is, you tend to avoid risks and overdocument.  My personal theory is that the reason is insistence on compliance instead of risk management.
• Revising FISMA:  I’ve said it time and time again, the law is good and doesn’t need to be changed, the execution is the part that needs work.

• An Open Letter to NIST About SP 800-30
• FISMA Report Card News, Formulas, and 3 Myths
• Ooh, “The Word” is out on S 3474
• How to Not Let FISMA Become a Paperwork Exercise
• A Funny Thing Happened Last Week on Capital Hill

And by “kerfluffle”, I mean these articles:

• GAO Privacy Report
• Technology Liberation Front
• Center for Democracy and Technology
• And how about an analysis of the Privacy Act from DOJ for background reasons?

Well, let’s talk about how privacy and the Government works with Uncle Rybolov (please hold the references to Old Weird Uncle Harold until we’re through with today’s lesson please).

We have a law, the Privacy Act of 1974.  Think about it, what significant privacy-wrenching activities happened just a couple of years prior?  Can we say “Watergate Scandal“?  Can we say “Church Committee“?  Suffice it to say, the early 1970s was an era filled with privacy issues and is where most of our privacy policy and law comes from.  Remember this for later:  this was the 1970’s!

Each of the various sections of the Privacy Act deals with a particular data type.  For instance, Title 13 refers to data collected by the Census Bureau when they’ll go count everybody in 2010.

The Privacy Act talks about the stuff that everybody in the Government needs to know about:  how you’re going to jail if you disclose this information to a third party.  For those of you who have ever been in the military or had to fill out a government form that required your social security number, the light in the back of your head should be going off right now because they all have the warnings about disclosure.

Remember to respect the privacy of the beach huts and chairs photo by Joe Shlabotnik

When it comes to IT security, the Privacy Act works like this:

• You realize a need to collect PII on individuals.
• You do a privacy impact assessment to determine if you can legally collect this data and what the implications of collecting the data are.
• You build rules about what you can do normally with the data once you have collected it.  This is called the “routine use”.
• You write a report on how, why, and about whom you’re collecting this information.  This is known as the “System of Record Notice”.
• You file this report with the Federal Register to notify the public.
• This IT system becomes the authoritative source of that information.

IE, no secret dossiers on the public.  We’ll suspend our disbelief in FISA for a minute, this conversation is about non-intelligence data collection.

Now the problem with all this is that if you stop and think about it, I was 1 year old when the Privacy Act was signed.  Our technology for information sharing has gone above and beyond that.  We can exchange data much much much more quickly than the Privacy Act originally intended.  As a result, we have PII everywhere.  Most of the PII is needed to provide services to the citizens, except that it’s a royal PITA to protect it all, and that’s the lesson of the past 2 years in Government data breaches.

Problems with the Privacy Act:

• The SORN is hard to read and is not easy to find.
• Privacy Act data given to contractors or “business partners” (aka, state and local government or NGOs) does not have the same amount of oversight as it does in the Government.
• Data given to the Government by a third-party is not susceptible to the Privacy Act because the Government did not collect it.  Wow, lots of room for abuse–waterboarding-esque abuse.
• Privacy Act procedures were written for mainframes.  Mainframes have been replaced with clusters of servers.  It’s easy to add a new server to this setup.  Yes, this is a feature.
• If you build a new system with the same data types and routine uses as an already existing SORN, you can “piggyback” on that existing SORN.
• It’s very easy to use the data in a way that isn’t on your “routine use” statement, thus breaking the entire privacy system.

Obviously, at this point, you should have gotten the hint that maybe we need to revise the Privacy Act.  I think GAO and OMB would agree with you here.

So, what alternatives do we have to the existing system?

• Make blanket data types and do a PIA and SORN on them regardless of where that data lies.
• Bend the Paperwork Reduction act and OMB guidance so that we don’t collect as much information.
• Make the Privacy Act more specific on what should be in SORN, PIA, and routine use statements.

To be honest, it seems like most of this is already in place, it just needs to get tuned a little bit so we’re doing the right things.  Once again, the scale of the Government’s IT infrastructure is keeping us from doing the right thing:    there isn’t enough time in the day to do PIAs on a per-server basis or to keep track of every little bit of data.  You have to automate our privacy efforts in some fashion.

And this is why, dear readers, I think the Government needs DLP solutions more than the private sector does.  Too bad the DLP vendors are stuck on credit cards and social security numbers.

• More on Georgia’s FISMA Reporting
• Current Government Security Initiatives
• New SP 800-60 is Out, Categorize Yerselves Mo Better
• Database Activity Monitoring for the Government
• Transparency in Government: Just Give us the Data!