I taught a 2-day seminar yesterday and the day before on Certification and Accreditation (NIST SP 800-37).  It’s fun but tiring, and yesterday I definitely got worked pretty hard, teaching 800-53, 800-53A, and C&A in the SDLC

I like to teach because I always learn when I do it.  But then again, I learn when I blog, too.

Anyway, revelations from yesterday, and things that I don’t really have an answer to yet:

#1 We need a better tool than a POA&M because we’re trying to use them in 2 different ways.  For those of you who don’t govorit’ govie, a POA&M is a “Plan of Actions and Milestones”, what you in the civilian world would call an action items list, a punch-list, or even a list of vulnerabilities.  The problem is that we’re trying to use the POA&M both as a short-term tasklist and as a long-term strategic planning tool.  I need to be able to do both, and I’m not sure if one POA&M list is the end-all be-all.  What I really need is 2 lists, one with a 30-60-90-day scope that is the ISSO/Project Team’s view, and one that is a long-term 1-2-5-year scope to mitigate programatic, enterprise-wide vulnerabilities that require CapEx or other investment such as standing up a secondary data center to support DR/COOP/BCP/$FooFlavorOfTheMonth.

#2 We have 2 conflicting purposes in information security in Government.  One is presenting a zero-defects face to the world.  The other is being able to freely discuss problems so that we can get them fixed.  Understanding the dynamics between these 2 competing ideas is understanding why the Government succeeds in some areas and fails in others.  To be bluntfully honest, I don’t think that as a profession, security people have a good, valid model to deal with this conflict, and until we do, we will have a significant cultural obstacle to go around.

#3 As a government (and as an industry), we are good at the tactical level and fairly good at the operational level, but where we need peoples’ thought-power to go is towards the strategic level.  This is my big heartburn about FISMA report cards:  what we should be doing is to collect Government-wide metrics in order to answer questions that we need to understand before we make strategic decisions.  As it is right now, our strategic moves are ad-hoc and consist mostly of trying to upscale some good security concepts (FDCC, limiting Internet connections, etc) into something that might or might not work at such a huge, megalithic scale.

#4 We’ve bought into the fact that CISOs work for the CIO.  This is old-school stylie and I’m not convinced that this is the way to do it.  If you look at the security controls in SP 800-53, there are activities entirely out of scope of the IT department.  Usually these involve gates, guards, and guns; personnel security; and facilities management.  For the time being, the official response is that “well, the CISO has to work with the people in charge of those areas to get their job done” and I’m thinking that maybe we’ve done a disservice to the senior security officer in our agencies by not having them report directly to the agency head.  Maybe we need true CSOs to take care of the non-IT security aspects and a CISO to take care of the geekspace.

The funny thing to me is that some of our students come in expecting to get spoon-fed information on the one true way to do C&A, and what most of them walk away with is ideas for thought on what are the strengths and weaknesses to how we do business as Government information security people and how do we make it better.

The last thing that I noticed yesterday after all the classes were over:  we taught a C&A class and did not have a dedicated session on what a System Security Plan is and how to write one.  Deep down inside, I like this, because if you do the right things security-wise, you’ll find that the SSP practically writes itself.  =)

• My 2 Obsessions this Week
• Some Thoughts on POA&M Abuse
• Another Day, Another Vendor
• Towards Actionable Metrics
• Needed: Agency CSOs

Are we done with the Federal Desktop Core Configuration yet? Are we compliant with OMB Memo 07-11?? Have we staved off dozens of script-kiddies armed with nmap and some ‘sploits they downloaded from teh Intarweb, all through hardening our desktops to the one true standard?

No? I didn’t think we would. Of course, neither did the CISOs and other security managers out there in the agencies. It’s too much too fast, and the government is too large to turn on a time. Or even a quarter, for that matter. =)

Now get ready for a blamestorm at the end of the month. By that time, all the agencies are supposed to report on their status to OMB. It’s not going to be pretty, but it’s hardly unexpected.

So why haven’t we finished this yet? Inquiring minds want to know.

Well, it all goes back to the big question of “how many directions can today’s government CISO be pulled in?” Think about it: You’ve got IPV6, HSPD-12, all the PII guidance (Memo 06-16 et al), reducing Internet connections down to 50, aligning your IT systems with the Federal Enterprise Architecture, getting your Internet connections monitored by Einstein, and the usual administrative overhead. that’s too many major initiatives all at the same time, and it’s a good way to be torn in too many directions at the same time. In government-speak, these are all what we call “unfunded mandates”, and one is bad enough to cripple your budget, much less a handful of them.

Where we’re at right now with FDCC is that the implementers are finding out what applications are broken, and we’re starting to impact operations–not being able to get the job done. Yes, this is the desired effect, it puts the pressure on the OS vendors and the application vendors, and it’s a good thing, IMO–we won’t buy your software if it doesn’t support our security model, and we’ll take our $75B IT budget with us. Suddenly, it’s the gorilla of market pressure throwing its weight around, and the BSOFH inside me likes this.

Now don’t get me wrong, I’m a big believer in FDCC (for both the Government and with a payoff for the civilian world), and I think it’s security-sound once it’s implemented, but in order for it to work, the following “infrastructure” needs to be in place:

• An official image shared between agencies
• Ability to buy a hardened FDCC OS as part of purchasing the hardware
• Microsoft rolling FDCC into its standard COTS build that it offers to the rest of the world
• Applications that are certified to run on the “one standard to rule them all” and on a list so I can pick one and know that it works
• Security people who understand GPOs and that even though it’s a desktop configuration standard, it affects servers, too
• An automated tool to validate technical policy compliance (there, I said it, and in this space it actually makes sense for a change)

Until you have these things, what OMB is asking for the agencies to get squeezed between a vendor who can’t ship a default-hardened OS, lazy applications vendors who won’t/can’t fix their software, and the 5+ levels of oversight that are watching over the shoulder of the average ISSO at the implementation level. In short, we’re throwing the implementers under the bus and making them do our dirty work because at the national level we have failed to build the right kind of influence over the vendors.

Gosh, it sounds like this would go so much better if we phased in FDCC along with the next tech refresh of our desktops, doesn’t it? That’s how the “sane world” would tackle something like this. Not a sermon, just a thought. =)

• SCAP for Dummies
• Some Words From a FAR
• Sir Bruce Mentions FDCC, World Goes Nuts
• Et Tu, TIC?
• Reading Between the Letters G, A, and O

I’ve been thinking about SP 800-53 lately because almost all of our efforts in the information assurance world lately are revolving around a catalog of controls concept.

Advantages that you get with a catalog of controls:

• Standardization (Important when you’re dealing with auditors)
• A minimum level of due dilligence “across the board”
• Each control can have an objective/intent, implementation guidelines, and test cases to validate effectiveness
• Easy to score (my cynical readers can retort with “auditor checklist” any time now)
• Applicable to a workforce with varying degrees of training and ability (ie, you don’t all have to have PHDs in IA)

And the dark underbelly of a catalog of controls:

• People just do the bare minimum because that’s all they get credit for
• Controls still need to be tailored by highly-educated people
• Enforces a “one size fits all” mentality which doesn’t work in the real world
• Your security is not streamlined because you’re doing extra where you don’t need it and not enough where you do need it

If you had to recreate your own catalog of controls for internal and external use, how would you go about it?  Well, this is the approach that NIST used to make 800-53:

• Collect all the control requirements from the various applicable laws (FISMA, Privacy Act, etc)
• Collect all the control requirements from other applicable standards, policies, and procedures (PPD-63, OMB Memoranda)
• Collect best practices from vendors and experienced security managers
• Consider the control requirements from comparable control catalogs (27001, PCI, A-123, etc)
• Lump all the requirements together and take the high-water mark
• Add some housekeeping controls that have been implied to bridge the current-state with the desired-state (document your security controls, perform a formal risk assessment, etc)

So far, this all makes sense and is exactly how most of us would do it, right?  NIST even did us a HUGE favor and gave us a traceability matrix in the back of the book to show us where each control requirement came from.

Except for one thing:  this is a compliance-based model, and I’ve just described how to build your own compliance framework.  No, that wasn’t my intent to prove, I realized it as I recreated the process.

We live in a risk management world where what I really need to provide effective and adequate security is a control framework based on threat, risk, and countermeasure.  A catalog of controls does the first 2 for me, and what I end up with as the security practitioner downstream is just the list of countermeasures detatched from what we’re really trying to accomplish–the intent.

So there are 2 approaches that NIST took to minimize some of the negatives of the catalog of controls approach.  The first one is that they allow you to catagorize your system (FIPS-199) and pick a level of controls.  It’s not perfect by any means, but it does that first part of tailoring the controls into large, xtra-large, and jumbonormous-sized buckets so you can choose your own level of involvement.  Sadly, though, most often this process involves the managerial equivalent of throwing darts at a dartboard with H, M, and L written on it.  Yes, it’s easy, but the best thing you can do for security in the government is to pick the right size of security helping that you’re going to eat.

The second thing that NIST gives you is the ability to tailor your controls.  If you’re not doing business impact assessments for where you undershoot and overshoot the untailored 800-53 controls, you’re doing yourself a great injustice.

However, just like the compliance-driven model that it supports, a catalog of controls is only a 75% solution.  The geek in me cringes that we would be using a rock chisel for rocket surgery, but in effect that’s what we’ve done so far as an industry.  And yes, 75% is better than 0%, but it’s still 25% short of perfection.

Will our catalog of controls be around in 5 years?  I don’t know.  There might be other ways to do what we want to do, and I’m sure a couple bright and not-so-bright people would step forward with their opinions if you asked them.  I for one would like to see 2 control catalogs:  one based on the minimum level of compliance where you do not have an option to deviate (and kept very small), and a second catalog that breaks down into threat-risk-countermeasure tuples so that I can exclude controls based on the fact that the threat and subsequent risk does not exist.

After all, that’s the point of tailoring security controls:  to answer the age-old question “How much is enough?”

• Blow-By-Blow Commentary
• An Open Letter to NIST About SP 800-30
• Opportunity Costs and the 20 Critical Security Controls
• What the Government Looks for in a Product
• Special Publication 800-53 Revision 3 Workshop

OK, so the Government Accountability and Office delivered their testimony to Congress on the Government’s dismal state of security.  You can get the testimony here and check out some responses here and here.

My favorite 2 quotes: 

“Federal agencies continue to report progress in implementing key information security activities. The President’s proposed fiscal year 2009 budget for IT states that the federal government continues to improve information security performance relative to the certification and accreditation of systems and the testing of security controls and contingency plans.”

Followed by:

“An underlying cause for these weaknesses is that agencies have not fully or effectively implemented agencywide information security programs.”

Maybe I’m a bear of very little brain, but these sound like GAO is  contradicting itself.  How can things be getting better when they don’t exist?  Truth be told, from a government-wide view, you have to rely on metrics to give you a picture of how things are going, but at the end of the day, they’re still just that, indicators.  Of course, I haven’t worked with all 24 agencies, so maybe my worldview is pretty myopic.

Now, I don’t know about all of you, but I have yet to see an infosec program where there actually was excessive resources to get the job done.  As a result, in the sane world we have to prioritize:  is it worth my time and money to implement a better automated vulnerability scanning tool or mandatory drug testing for IT staff?

But here’s the rub:  in a compliancy-driven information security model, there is no way to priotitize what you need to get done.  It all bears the same weight.  In the world of GAO, if you can not prove that a control exists, you have not implemented a security program.

We’ve talked metrics before, and this has always been one of my problems with the way the Government is doing FISMA reporting right now:  if your metrics are not actionable–that is, you do not use the results to make changes–all you are doing is security management through shame.

Now the things that are happening, I see this is some fairly good analysis of the numbers behind the numbers behind the numbers and what we’re going to see over the next couple of years:

• The Information Systems Security Line of Business:  I think this is a good thing, but it has some issues that the Government needs to resolve before it becomes more than just a pet project.

• Federal Desktop Core Configuration:  Fantastic idea, but the implementation is harder than OMB thinks it will be–you can’t just shake the magic FISMA wand at your LAN and think that the legacy applications will still work.  Now for those of you who think FDCC is just the end, wait for the Router Core Configuration and Server Core Configuration.

• SmartBUY:  Centralized COTS buying.  This is pretty happy, although it’s tangentially related to security, it’s more of an overall IT management strategy.

• Trusted Internet Connections initiative:  I like this, I really do, but implementation is a bear.

• Clarify requirements for testing and evaluating security controls:  Auditors need to say this:  “We could have done a better auditing job but the standard was lacking”.  Yes, the standards for gathering metrics suck, but they’re getting better as we go.  My opinion is that in order to evaluate security controls, you need to have a definitive set of security controls in the first place, but if you’re doing that, you’re looking at compliance and “audit risk” not mission risk and risk to IT investments.

• Enhance FISMA reporting requirements:  The standardes have been evolving for 5 years and will continue to evolve.  So far we’ve been gathering metrics for the sake of gathering them, now it’s time to figure out specifically what we want to know and tailor the metrics to that question.

• Consider conducting FISMA-mandated annual independent evaluations in accordance with audit standards or a common approach and framework:  Um, I thought we already had this.  Maybe I’m just slow-thinking today.

So, the Guerilla CISO’s takeaways from this conversation:

• If you look at the metrics and see that they are improving, what more do you want?
• Government needs to learn how to prioritize.  Their metrics should support this goal.
• It’s the job of an auditor to always find something and to always CYA by spreading stories of woe and gloom.  Anticipate that this will happen and don’t be outraged when it does.

• Comments on the Annual OMB Security Report to Congress
• GAO’s 5 Steps to “Fix” FISMA
• 20 Critical Security Controls: What They Did Right and What They Did Wrong
• More GAO Testimony
• Cage Match: OMB Report V/S GAO Report, Only One Comes Out Alive

I’m mulling over some ideas this week.  It’s probably the death-by-CBT that being a new hire has become over the past 5 years.

I work with a ton of accountants in my new job.  Obviously, they’re CPAs and Uber-CPAs, and for the most part, they’re proud of the valuable service that accountants bring to their community and to the US economy as a whole.  $Diety bless them, there is no way I have the patience to do what they do on a daily basis, and from what I gather, they feel the same way about what I do.  However, while learning the history of the accounting profession, I can’t help but notice a couple of things:

• CPAs have some strange ideas and a rich history, cross-training has some merit.
• Accountants are obsessed with compliance.  More on this later.
• Attestation that a company has not cooked the books and is headed into a downward Enron/Worldcom/Hindenburg-esque firey crash is a good thing.
• Accountants highly value attestation.
• Accountants are typically weak on planning and project management (yes, making a generalization here).
• Accountants understand risk, but only qualitative dollar risks that can be measured via actuarial means.
• Accountants perform unnatural acts with spreadsheets.
• I have to be very careful when I mention the word “controls” because somewhere in there an interpreter is needed.

And then somewhere around day 3 of CBT-Hell, it dawned on me:  we’re taking the models for accounting and applying them en-mass to information security management.  Explains quite a bit of things, doesn’t it?

Stop and think about the Federal government.  Who is really in charge of security?  Not NIST, they just write standards.  The correct answer is the Office of Management and Budget (OMB) and the Goverment Accountability Office (GAO).  In other words, the accountants and the auditors.  It’s one of those things that make you go “hmmmm”.

Now, some of this is a necessary evil.  Any good CISO will tell you that whoever controls the money controls the security, just ask a security manager who has had their budget taken away.  As a profession, we’re tied to the economics of security just as tightly as the accountants are tied to the security of IT systems to maintain integrity of accounting systems.  It’s scary when you think about it, although I don’t know if it’s scarier for them or for us. =)

There’s an obvious reason why we adopted the accounting models for security:  expediency.  In the typical CIO’s option of build-buy-outsource, we outsourced the creation and maintenance of our governance model to the accountants.  And just like outsourcing to a managed service provider who has in turn offshored some of their operations, we might not be getting what we planned at the very beginning.

But now we’re getting to the limitations of using that model:

• For the most part, we are an industry driven by vulnerabilities and risk management.
• Accounting is driven by law and oversight boards.
• What laws we have are very broad because the laws cannot keep pace with the technology.
• Information security is not reported to oversight agencies/boards/whatever to the same level of granularity as is financial information.  Imagine reporting your WSUS stats on your SEC filing.
• Even the accountants are starting to agree on a more risk-based model than a compliance model.  The latest guidance from the SEC on SoX 404 called AS-5 is a step in this direction.
• IT has a higher level of acceptable risk on both an organizational and personal level than accounting.
• The accounting model is focused on audit and oversight.  Typically this is at the end of development and/or annually.
• True success in information security management needs a full-SDLC approach.

So this is what I’m mulling over:  we maybe have a need for some better tailoring of what we’re doing.  What I really want is a large-scale method for security management that cuts out the parts of the accounting model that don’t work.

Not that I have an answer today, but it’s something I’m using my spare brain cycles to figure out.  Who knows, maybe I’ll come full-circle and reinvent the current state. =)

• In Search of a Better Catalog of Controls
• Workin’ for the ‘Counters: an Analysis of my Love-Hate Relationship with the CPAs
• Ack! With the Mandates!
• An Open Letter to NIST About SP 800-30
• It’s a Problem of Scale!

OK, the title is for hyperbole purposes, but I think that the current Government security model doesn’t work with the way we do Software as a Service (SaaS) today. =)

Karen Evans has officially thrown her hat in the ring to support Software as a Service. I agree, but I think it’s also harder to accomplish than OMB might think. I’ve said this before, but information sharing, security, and SaaS doesn’t fit into The Government Way of Doing Things ™, and that needs to get fixed.

Hurdles that the government needs to overcome for SaaS (and I guess Lines of Business as a whole):

• Personnel Security: How do I know that my user population is cleared to view the information that I’m providing, and how do I ensure that I get notification when they leave? (note: HSPD-12 in theory could fix this)
• Trustworthiness of Service Provider: How do I trust a server and/or application operated by another agency?
• Interconnectivity: Can we route SaaS traffic over the Internet or do we need to interconnect our LAN/WANs to get to the resources?
• Assurance: How do I prove to a customer agency that my solution meets their security needs without running into “Not Invented Here” problems?
• Certification and Accreditation: If this is a mission-critical system for me, how do I account for the security of it when it’s a low-impact system for the service provider? What do I do if I want the service provider to increase some of the security on the system?
• Guidance: We have OMB telling us what they want to see accomplished (which is SaaS in general) but there isn’t any formal guidance on how to do this and still stay within the bounds of our security framework.

All of the current guidance for information sharing between IT systems is based on IP connectivity between 2 LAN/WANs. The process (SP 800-47 if you want to research) breaks down like this:

• Certify and Accredit the networks of both agencies.
• Do a Risk Assessment of the connection.
• Establish a Memorandum of Understanding (manager-level, we like you, you like us, these are the rules on what you can do with our data).
• Make a “firewall sandwich with circuits betwixt” with each side owning their own firewall so if they decide they don’t want to play anymore, they can unilaterally kill the connection.
• Establish an Interconnect Agreement (technical level, routing and firewall configuration, technical POCs, etc)
• Make the connection.

Nowhere in there is anything we can use for SaaS. Believe it or not, I’ve seen well-intentioned IA analysts trying to get people to sign an interconnect agreement for an RSS feed out on a website when in all actuality, the interconnect is with the Internet and it’s your responsibility as a feed customer to sanitize the input before you do anything with it.

SP 800-95 covers web services but from a Service-Oriented Architecture (SOA) angle but doesn’t talk about the interaction between the players and processes.

Hence, the Guerilla CISO’s guide to SaaS in the government:

• Determine that you want to be a vendor for SaaS. You can be G2G or C2G.
• Pick a security baseline. I usually recommend a Moderate FIPS-199 because it will apply in most contexts.
• Build your SaaS system.
• Certify and Accredit your SaaS system.
• Provide a SaaS kit to your supported agencies containing the following information:
  • Service delivery options (interconnect or via Internet)
  • API/Service Specifications
  • System Security Plan
  • Security Test and Evaluation Report
  • Sign a Memorandum of Agreement that is basically an Acceptable Use Policy at a department level.
• Perform security upgrades at a partial cost to the supported client agency.
• Periodic client agency meetings with the service provider.

• HR 5983–DHS Now Responsible for Contractor Security
• Lines of Business, Relationships, and Trustability
• Alternative Uses for System Security Plans
• Response to “What is Information Assurance – The Video”
• Compensating Controls