Rybolov Note: this is part 2 in a series about S.773.  Go read the bill here.  Go read part one here. Go read part 3 here. Go read part four here.  Go read part 5 here. =)

SEC. 7. LICENSING AND CERTIFICATION OF CYBERSECURITY PROFESSIONALS. This section has received quite a bit of airtime around the blagosphere.  Everybody thinks that they’ll need some kind of license from the Federalies to run nessus.  Hey, maybe this is how it will all end up, but I think this provision will end up stillborn.

I know the NIST folks have been working on licensing and certification for some time, but they usually run into the same problems:

• Do we certify individuals as cybersecurity professionals?
• Do we certify organizations as cybersecurity service providers?
• What can the Government do above and beyond what the industry provides? (ISC2, SANS, 27001, etc)
• NIST does not want to be in the business of being a licensure board.

Well, this is my answer (I don’t claim that these are my opinion):

• Compulsory: the Government can require certifications/licensure for certain job requirements.  Right now this is managed by HR departments.
• Existing Precedent: We’ve been doing this for a couple of years with DoDI 8570.01M, which is mandatory for DoD contracts.  As much as I think industry certification is a pyramid scheme, I think this makes sense in contracting for the Government because it’s the only way to ensure some kind of training for security staff.If the Government won’t pay for contractor training (and they shouldn’t) and the contractor won’t pay for employees to get training because their turnover rate is 50% in a year, it’s the only way to ensure some kind of training and professionalization of the staff.  Does this scale to the rest of the country?  I’m not sure.
• Governance and Oversight: The security industry has too many different factions.  A Government-ran certification and license scheme would provide some measure of uniformity.

Honestly, this section of the bill might make sense (it opens up a bigger debate) except for one thing:  we haven’t defined what “Cybersecurity Services” are.  Let’s face it, most of what we think are “security” services are really basic IT management services… why should you need a certification to be the goon on the change control board.  However, this does solve the “problem” of hackers who turn into “researchers” once they’re caught doing something illegal.  I just don’t see this as that big of a problem.

Verdict: Strange that this isn’t left up to industry to handle.  It smells like lobbying by somebody in ISC2 or SANS to generate a higher demand for certs.  Unless this section is properly scoped and extensively defined, it needs to die on the cutting room floor–it’s too costly for almost no value above what industry can provide.  If you want to provide the same effect with almost no cost to the taxpayers, consider something along the 8570.01 approach in which industry runs the certifications and specific certifications are required for certain job titles.

SEC. 8. REVIEW OF NTIA DOMAIN NAME CONTRACTS. Yes, there is a bunch of drama-llama-ing going on between NTIA, ICANN, Verisign, and a cast of a thousand.  This section calls for a review of DNS contracts by the Cybersecurity Advisory Panel (remember them from section 3?) before they are approved.  Think managing the politics of DNS is hard now?  It just got harder–you ever try to get a handful of security people to agree on anything?  And yet, I’m convinced that either this needs to happen or NTIA needs to get some clueful security staffers who know how to manage contracts.

Verdict: DNSSEC is trendy thanks to Mr Kaminski.  I hate it when proposed legislation is trendy.  I think this provision can be axed off the bill if NTIA had the authority to review the security of their own contracts.  Maybe this could be a job for the Cybersecurity Advisor instead of the Advisory Panel?

SEC. 9. SECURE DOMAIN NAME ADDRESSING SYSTEM. OK, the Federal Government has officially endorsed DNSSEC thanks to some OMB mandates.  Now the rest of the country can play along.  Seriously, though, this bill has some scope problems, but basically what we’re saying is that Federal agencies and critical infrastructure will be required to implement DNSSEC.

Once again, though, we’re putting Commerce in charge of the DNSSEC strategy.  Commerce should only be on the hook for the standards (NIST) and the changes to the root servers (NTIA).  For the Federal agencies, this should be OMB in charge.  For “critical infrastructure”, I believe the most appropriate proponent agency is DHS because of their critical infrastructure mission.

And as for the rest of you, well, if you want to play with the Government or critical infrastructure (like the big telephone and network providers), it would behoove you to get with the DNSSEC program because you’re going to be dragged kicking and screaming into this one.  Isn’t the Great InfoSec Trickle-Down Effect awesome?

Verdict: If we want DNSSEC to happen, it will take an act of Congress because the industry by itself can’t get it done–too many competing interests.  Add more tasks to the agencies outside of Commerce here, and it might work.

Awesome Capitol photo by BlankBlankBlank.

SEC. 10. PROMOTING CYBERSECURITY AWARENESS. Interesting in that this is tasked to Commerce, meaning that the focus is on end-users and businesses.

In a highly unscientific, informal poll with a limited sample of security twits, I confirmed that nobody has ever heard of Dewie the Webwise Turtle.  Come on, guys, “Safe at any speed”, how could you forget that?  At any rate, this already exists in some form, it just has to be dusted off and get a cash infusion.

Verdict: Already exists, but so far efforts have been aimed at users.  The following populations need awareness: small-medium-sized businesses (SMBs), end-users, owners of critical infrastructure, technology companies, software developers.  Half of these are who DHS is dealing with, and this provision completely ignores DHS’s role.

SEC. 11. FEDERAL CYBERSECURITY RESEARCH AND DEVELOPMENT. This section is awesome to read, it’s additions to the types of research that NSF can fund and extensions of funding for the existing types of research.  It’s pretty hard to poke holes in, and based on back-of-the-envelope analysis, there isn’t much that is missing by way of topics that need to be added to research priorities.  What I would personally like to see is a better audit system not designed around the accounting profession’s way of doing things.  =)

Verdict: Keep this section intact.  If we don’t fund this, we will run into problems 10+ years out–some would say we’re already running into the limitations of our current technology.

SEC. 12. FEDERAL CYBER SCHOLARSHIP-FOR-SERVICE PROGRAM. This is an existing program, and it’s pretty good.  Basically you get a scholarship with a Government service commitment after graduation.  Think of it as ROTC-light scholarships without bullets and trips to SW Asia.

Verdict: This is already there.  This section of the bill most likely is in to get the program funded out to 2014.

• Blow-By-Blow on S.773–The Cybersecurity Act of 2009–Part 1
• Blow-By-Blow on S.773–The Cybersecurity Act of 2009–Part 3
• Blow-By-Blow on S.773–The Cybersecurity Act of 2009–Part 4
• Blow-By-Blow on S.773–The Cybersecurity Act of 2009–Part 5
• The World Asks: is S.773 Censorship?

Some of my friends (and maybe myself) will be teaching the NIST Framework for FISMA in May and June with Potomac Forum.   This really is an awesome program.  Some highlights:

• Attendance is limited to Government employees only so that you can talk openly with your peers.
• Be part of a cohort that trains together over the course of a month.
• The course is 5 Fridays so that you can learn something then take it back to work the next week.
• We have a Government speaker ever week, from the NIST FISMA guys to agency CISOs and CIOs.
• No pitching, no marketing, no product placement (OK, maybe we’ll go through DoJ’s CSAM but only as an example of what kinds of tools are out there) , no BS.

See you all there!

• Security Automation Developers Conference Slides
• C&A Seminar, October 15th and 16th
• Comments on SCAP 2008
• New SP 800-60 is Out, Categorize Yerselves Mo Better
• The “Off The Record” Track

We’ve got another good US Government Security Certification and Accreditation (C&A) Seminar/Workshop coming up at the end of March with Potomac Forum.

Graydon McKee (Ascension Risk Management and associated blog) and Dan Philpott (Fismapedia Mastermind and Guerilla-CISO Contributor) are going to the core of the instruction, with a couple others thrown in to round it all out.  I might stop by if I have the time.

What we promise:

• An opportunity to hear NIST’s version of events and what they’re trying to accomplish
• An opportunity to ask as many questions as you possibly can in 2 days
• Good materials put together
• An update on some of the recent security initiatives
• An opportunity to commiserate with security folks from other agencies and contractors
• No sales pitches and no products

See you all there!

• C&A Seminar, October 15th and 16th
• Building A Modern Security Policy For Social Media and Government
• Some Comments on SP 800-39
• C&A Seminar in August, Instructor-to-Coolness Ratio Goes Up!
• NIST Framework for FISMA Dates Announced

The accreditation decision is one of the most key activities in how the US Government secures its systems. It’s also one of the most misunderstood activities. This slideshow aims to explain the role of the Authorizing Official and to give you some understanding into why and how accreditation decisions are made.

I would like to give a big thanks to Joe Faraone and Graydon McKee who helped out.

The presentation is licensed under Creative Commons, so feel free to download it, email it, and use it in your own training.

• Your Friendly Neighborhood C&A Podcast Panel
• Certification and Accreditation Seminar, March 30th and 31st
• Building A Modern Security Policy For Social Media and Government
• DojoCon 2009 Presentation
• Massively Scaled Security Solutions for Massively Scaled IT

Back in 1995 the junior high school students around the world were taken in by a sensationalized and carefully marketed hoax film called Alien Autopsy. Alien Autopsy was in fact a cheap film purporting to be actual footage of an actual autopsy of the cadaver of an extraterrestrial. The film was marketed as footage shot during the famous 1947 Roswell incident.

Alien Autopsy photo by jurvetson.

Well, back in 1995 I was in a mood for a good laugh so I popped up some popcorn, chilled a six-pack of Mountain Dew and kicked up my feet for a little silly entertainment. A couple of friends came over just in time for the show. So, I popped more popcorn, chilled more drinks and we all had a great time giggling, guffawing, and generally acting like a bunch of nitwits having some good clean fun.

Then in 2005, my wife asked if I could sit down with her to watch something called Grey’s Anatomy. Thinking that I was about to relive a guilty pleasure from ten years before, I readily agreed. Let’s face it, a show called Grey’s Anatomy could only be a sequel to the 1995 Alien Autopsy.

Well, having been fooled, I shared my mistake and agony with the guys at work the next day. To say the least, they were amused at the story but entirely at my expense. Some mistakes in life should just never be mentioned again.

I hope that is not the case with today’s comments. Today, I’d like to encourage you all to down load and read my paper on the History of Digital Forensics (.pdf caveat applies). It is based on a paper I presented at NIST’s annual digital forensics conference. However, since the slides from briefings do not read well, I converted the presentation to prose. Dissect it as you think appropriate. That is to say, let me know what you think.

• Digital Forensics: Who should make the keys?
• Ed Bellis’s Little SCAP Project
• Database Activity Monitoring for the Government
• Security Automation Developers Conference Slides
• Barcode Hacking

Rybolov really struck a note with me (as he usually does) with his blog entry with his decision that S.3474 was a bad thing. It reminds me of a conversation I had with a friend recently. Basically she ask me why bad thing happen even after smart people put their heads together and try to deal with the problem before facing a crisis. Intrigued with her question, I asked her what specifically she was asking about. She shared that she had been thinking about the tragedy of the Titanic sinking.

Of course she was referring to the sinking of the passenger ship RMS Titanic on the evening of 14 April 1912. She made two points, first that the experts declared that the ship was “unsinkable” – how could they be so wrong. Second, she wondered how the ship could be so poorly equipped with boats and safety equipment such that there was such great loss of life.

The Titanic’s Disaster photo by bobster1985.

Little did she know that I have had an odd fascination with the Titanic disaster since childhood and have basically read much of the common public material about the event. So, I replied that that no expert had ever declared her unsinkable, that it was basically something that was made up by the press and the dark spineless things that hang around the press. However, I added the designers and owners of the ship had made much of her advanced safety features when she was launched. A critical feature was including water-tight bulkheads in her design. This was something of an advanced and novel feature at the time. What it meant was that you could poke a pretty big hole in the ship, and as long as the whole was not spread over several of these water-tight compartments she would stay afloat. The problem was that the iceberg that she hit (the Titanic, not my friend), ignored all of this a tore a big gash along about a third of the length of the ship.

So, my friend pressed again about the lack of safety equipment, especially lifeboats. I told her that the problem here was that the Titanic indeed did meet all of the safety requirements of the time. And that a big part of the problem was that the safety requirements were drafted in 1894 at a time when there were rapid changes and in the size and design of ships of this kind. Those regulations indicated that all passenger ships over 10,000 tons required 16 life boats, and that’s how many the Titanic had. At the time the regulations were written there were hardly any ships over 10,000 tons in size. However, when Titanic was launched she was designed to be over 50,000 tons when fully loaded. The fact was that if each of these lifeboats was fully loaded they could barely hold half of the of the passengers and crew of the ship if fully loaded. What is worse, when the ship did sink, not all of the boats were usable because of speed and angle in which the ship began sinking.

So, the bottom-line was that when the Titanic was reviewed by the safety accountants, they took out their check-list and went over the ship with a fine tooth comb. When the day was done the ship fully met all the safety criteria and was certified as safe.

This is where I see the parallels between root causes of the Titanic disaster and the odd situation we find ourselves in today in terms of IT security. Security by checklist –especially out of date checklists—simply doesn’t work. Moreover, the entire mental framework that mixes up accounting practices and thoughts with security discipline and research is an utter failure. Audits only uncover the most egregious security failures. And, they uncover them at a point in time. The result is that audits can be gamed, and even ignored. On the other hand, formal reviews by experienced security professionals are rarely ignored. Sometimes not all of the resources are available to militate against some of the vulnerabilities pointed out by the professionals. And sometimes there is debate about the validity of specific observations made by security professionals. But, they are rarely ignored.

Interesting enough, because of the mixed IT security record of many government agencies, Congress is proposing – more audits! It seems to me what they should be considering is strengthening the management of IT security and moving from security audits often performed by unqualified individuals and teams toward security assessments conducted by security professionals. And since professionals are conducting these proposed assessments, they should be required to comment on the seriousness of deficiencies and possible mitigation actions. An additional assessment that the professionals should be required to report on is the adequacy of funding, staffing and higher management support. I don’t really see any point in giving a security program a failing grade if the existing program is well managed but subverted and underfunded by the department’s leadership.

• FedRAMP: It’s Here but Not Yet Here
• In Other News, I’m Saying “Nyet” on S.3474
• GAO’s 5 Steps to “Fix” FISMA
• Blow-By-Blow on S.773–The Cybersecurity Act of 2009–Part 2
• “Machines Don’t Cause Risk, People Do!”