And here we have it, a bill introduced by Senators Carper and Lieberman to increase security in the Government, known as FISMA 2008. I’m still waiting on the text to appear on the Thomas entry, but I’ll go through the major provisions from the congressional record.

Article from NextGov

Thomas Reference

Congressional Record of the Bill’s Introduction and text (Starts on CR 8388 and goes through CR 8391)

Major provisions:

• Changes some definitions of “assessment”, “audit” and “evaluation”. OK, I had to do some research on this one.  Thankfully, this is all online.  Sidenote: it’s not Section 3545 as per the bill, it’s Section 3535.  Basically this is just rewording and rescoping of annual audits to be written the way it should have been in the first place.
• Creates a CISO position at each agency. Hey, I thought this was already created by FISMA.  What we need is not CISOs that work for the CIO, what we need are agency CSOs (I’ll even take an agency Chief Risk Officer) that have authority over all of security, not just IT geek concerns.
• Creates a CISO Council. Fantastic idea, how come I didn’t think of it?
• Qualifications for CISOs. Not a bad idea, but the bill doesn’t elaborate too much.
• Responsibilities for CISOs. This is an interesting section.  Much of this is in guidance from NIST/DISA/CNSS already.  I like most of these measures, but I’m not sure that they need to be codified into law except for the pieces that reside outside of the agencies, like the coordination with US-CERT.  Putting the CISO’s responsibilities into law does give the CISO more teeth if they need it, but you have to wield the law carefully.

The Law photo by F.S.M.

From the NextGov article and the congressional record:

“Our bill empowers chief information security officers to deny access to the agency network if proper security policies are not being followed. If we are going to hold these hardworking individuals accountable in Congress for information security, then we should give them the authority to do so,” said Carper.

Um, yeah, we’ve given them the authority in this bill, but my problem is that it completely removes the DAA/AO/mission owners from the picture–the CISO is now responsible for the secure operations of IT systems and has disconnect authority.

I think that philosophically this bill is a step backwards.  The more progressive thought is that security is the responsibility of the agency head and the mission owners and that the CISO just provides support as a subject matter expert.  Under this bill, we’re back to a world where the CISO is the sole decision-maker when it comes to security.  Wow, that’s so… 1990’s-ish.

However, we all know that the CISOs are the people getting the security job done from day to day, and this bill makes sense if you assume that the agency heads and DAAs/AOs have 0 interest or skills to assist in the security of their data.  That might or might not be true, I’ll leave it up to you to decide.

Questions for today are these (and yes, I want to hear what you think):

• Are we willing to scrap the “business/system owner” concepts that our security management processes are modeled around?
• Are we willing to admit that the DAA/AO concept is a failure because of lack of understanding and capabilities on their part?
• Are the mission owners willing to take an outage on their supporting IT infrastructure because the CISO took the system offline because they didn’t secure the system properly in the first place?
• Can we rely on a management technique where the stakeholders are removed from the decisionmaking of a trained expert?

• Ooh, “The Word” is out on S 3474
• In Other News, I’m Saying “Nyet” on S.3474
• Some Comments on SP 800-39
• Needed: Agency CSOs
• When the News Breaks, We Fix it…

FAR: it’s the Federal Acquisition Regulation, and it covers all the buying that the government does.  For contractors, the FAR is a big deal–violate it and you end up blackballed from Government contracts or having to pay back money to your customer, either of which is a very bad thing.

In early August, OMB issued Memo 08-22 (standard .pdf caveat blah blah blah) which gave some of the administratrivia about how they want to manage FDCC–how to report it in your FISMA report, what is and isn’t a desktop, and a rough outline on how to validate your level of compliance.

Now I have mixed feelings about FDCC, you all should know that by now, but I think the Government actually did a decent thing here–they added FDCC (and any other NIST secure configuration checklists) to the FAR.

Check this section of 800-22 out:

On February 28, 2008, revised Part 39 of the Federal Acquisition Regulation (FAR) was published which reads:
PART 39-ACQUISITION OF INFORMATION TECHNOLOGY
1. The authority citation for 48 CFR part 39 continues to read as follows: Authority: 40 U.S.C. 121(c); 10U.S.C. chapter 137; and 42 U.S.C. 2473(c).
2. Amend section 39.101 by revising paragraph (d) to read as follows:
39.101 Policy.
* * * * *

(d) In acquiring information technology, agencies shall include the appropriate IT security policies and requirements, including use of common security configurations available from the NIST’s website at http://checklists.nist.gov. Agency contracting officers should consult with the requiring official to ensure the appropriate standards are incorporated.

Translated into English, what this means is that the NIST configurations checklists are coded into law for Government IT purchases.

This carries a HUGE impact to both the Government and contractors.  For the Government, they just outsourced part of their security to Dell and HP, whether they know it or not.  For the desktop manufacturers, they just signed up to learn how FDCC works if they want some of the Government’s money. 

Remember back in the halcyon days of FDCC when I predicted that one of the critical keys to success for FDCC was to be able to buy OEM desktops with the FDCC images on them.  It’s slowly becoming a reality.

Oh what’s that, you don’t sell desktops?  Well, this applies to all NIST configuration checklists, so as NIST adds to the intellectual property in the checklists program, you get to play too.  Looking at the DISA STIGs as a model, you might end up with a checklist for literally everything.

So as somebody who has no relation to the US Federal Government, you must be asking by now how you can ride the FDCC wave?  Here’s Rybolov’s plan for secure desktop world domination:

• Wait for the government to attain 60-80% FDCC implementation
• Wait for desktops to have an FDCC option for installed OS
• Review your core applications on the FDCC compatibility list
• Adopt FDCC as your desktop hardening standard
• Buy your desktop hardware with the image pre-loaded
• The FDCC configuration rolls uphill to be the default OS that they sell
• ?????
• Profit!

And the Government security trickle-down effect keeps rolling on….

Cynically, you could say that the OMB memos as of late (FDCC, DNSSEC) are very well coached and that OMB doesn’t know anything about IT, much less IT security.  You probably would be right, but seriously, OMB doesn’t get paid to know IT, they get paid to manage and budget, and in this case I see some sound public policy by asking the people who do know what they’re talking about.

While we have on our cynical hats, we might as well give a nod to those FISMA naysayers who have been complaining for years that the law wasn’t technical/specific enough.   Now we have very static checklists and the power to decide what a secure configuration should be has been taken out of the hands of the techies who would know and given to research organizations and bureaucratic organizations who have no vested interest in making your gear work.

Lighthouse From AFAR photo by Kamoteus.

• Comments on SCAP 2008
• No, FISMA Doesn’t Require That, Silly Product Pushers
• Federated Vulnerability Management
• Current Government Security Initiatives
• When the News Breaks, We Fix it…

Post summary: We’re not ready yet culturally.

What spurred this blog post into being is this announcement from ServerVault and Apptis about a Federal Computing Cloud.  I think it’s a pretty ballsy move, and I’ll be watching to see if it works out.

Disclaimer being that at one time I managed security for something similar in a managed services world, only it was built by account with everything being a one-off.  And yeah, we didn’t start our organization the right way, so we had a ton of legacy concepts that we could never shake off, more than anything else about our commercial background and ways of doing things.

Current Theory on Cloud Computing photo by cote.

The way you make money in the managed services world is on standardization and economy-of-scale.  To us mere mortals, it means the following:

• Standardized OS builds
• Shared services where it makes sense
• Shared services as the option of choice
• Split your people’s time between clients
• Up-charge for non-standard configurations
• Refuse one-off configurations on a case-by-case basis

The last 2 were our downfall.  Always eager to please our clients, our senior leadership would agree to whatever one-offs that they felt were necessary for client relationship purposes but without regard to the increased costs and inefficiency when it came time to implement.

Now for those of you out in the non-Government world, let me bring you to the conundrum of the managed services world:  shared services only works in limited amounts.  Yes, you can manage your infrastructure better than the Government does, but they’ll still not like most of it because culturally, they expect a custom-built solution that they own.  Yes, it’s as simple as managing the client’s expectations of ownership v/s their cost savings, and I don’t think we’re over that hurdle yet.

And this is the reason: when it comes to security and cloud computing, the problem is that you’re only as technically literate as your auditors are.  If they don’t understand what the solution is and what the controls are around it, you do not have a viable solution for the public sector.

A “long time ago” (9000 years at least), I created the 2 golden rules for shared infrastructure:

• One customer cannot see another customer.
• One customer cannot affect another customer’s level of service.

And the side-rules for shared infrastructure in the public sector:

• We have a huge set of common controls that you get the documentation to.  It will have my name on it, but you don’t have to spend the money to get it done.
• It’s to my benefit to provide you with transparency in how my cloud operates because otherwise, my solution is invalidated by the auditors.
• Come to us to design a solution, it’s cheaper for you that way.  I know how to do it effectively and more cheaply because it’s my business to know the economics of my cloud.
• You have to give up control in some ways in order to get cost savings.
• There is a line beyond which you cannot change or view because of the 2 golden rules.  The only exception is that I tell you how it’s made, but you can’t see any of the data that goes into my infrastructure.
• If I let you audit my infrastructure, you’ll want to make changes, which can’t happen because of the 2 golden rules.
• I’ll be very careful where I put your data because if your mission data spills into my infrastructure, I put myself at extreme risk.

So, are ServerVault and Apptis able to win in their cloud computing venture?  Honestly, I don’t know.  I do think that when somebody finally figures out how to do cloud computing with the Federal Government, it will pay off nicely.

I think Apptis might be spreading themselves fairly thin at this point, rumor has it they were having some problems last year.  I think ServerVault is in their comfort space and didn’t have to do too much for this service offering.

I can’t help but think that there’s something missing in all of this, and that something is a partnering with the a sponsoring agency on a Line of Business.  FEA comes to mind.

• NIST Cloud Conference Recap
• Reinventing FedRAMP
• Categories of Security Controls in Outsourcing
• Database Activity Monitoring for the Government
• Security Assessments as Fraud, Waste, and Abuse

Post #9678291 on why people don’t understand what FISMA really is:  Secure64 DNSSEC Press Releases.

“FISMA Act encourages U.S. government agencies to configure their DNS servers to the DNSSEC security specifications set by the National Institute of Standards and Technology, and it has been reported that the federal government’s Office of Management and Budget (OMB) plans to begin enforcing DNSSEC requirements through an auditing process, setting the standard for DNS best practices.”

Yep, if you stamp FISMA on it, people will buy it, maybe in your PR department’s wettest and wildest dreams.  Guys, it’s been 6 years, that kind of marketing doesn’t work nowadays, mostly because we spent ourselves into oblivion buying junkware similar to yours and now we’re all jaded.

Now don’t get me wrong, DNSSEC is a good thing, especially this month.  But there is something I need to address:  FISMA requires good security management with a dozen or so key indicators, not a solution down to the technical level.  Allusions to OMB are just FUD, FUD, and more FUD because unless it’s in a memo to agency heads, it’s all posturing–something everybody in this town knows how to do very well.  OMB would rather stay out of mandating DNSSEC and maybe give a “due date” once NIST has a final standard.

My one word of wisdom for today:  anybody who tries to sell a product and uses FISMA as the “compelling event” has no clue what they’re talking about.

• Some Words From a FAR
• When the News Breaks, We Fix it…
• Comments on SCAP 2008
• GAO’s 5 Steps to “Fix” FISMA
• How to Not Let FISMA Become a Paperwork Exercise

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

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