Remember the last post I did about the Business Reference Model? If you don’t, go read it now. We’re about to get freaky on it.

Have you ever had a chance to give everybody the opportunity to categorize their business functions for confidentiality, integrity, and availability as high, moderate, and low ala FIPS-199? You’ll know the effect if you’ve ever had to build a corporate website–everybody wants a link on the front page. The purchasing team wants a link on the front page so that prospective vendors can reach them, the HR people want the entire corporate employees’ manual online.

It’s a little organizational behavior factoid: everybody thinks that the silo that they operate in makes the business run. Translate that into security and we’ll find out that, left to their own devices to determine criticality, every business department lists its IT systems as high-criticality. Don’t tell my HR department, but if the personnel management system disappeared for a week, we would still continue to monitor networks. Even if the payroll system were to implode and we had to rebuild it from scratch, it wouldn’t matter unless it happened on or just before a payday–we would still be making money as a business. Yes, have an outage for 2 weeks and our employees would pretend to work because we’re pretending to pay them, and it would be just like the Brezhnev era. =)

Add in to the mix the fact that if your system is high-criticality, you get more money (in theory, that’s how the government determines the budget, reality may be a little different), and everybody in the government has a high-criticality system. In a classic case of “NIST to the rescue”, they have developed a totally awesome document that nobody reads called Special Publication 800-60. It’s more than everything a data and system classification geek would need to fall in love with.

Don’t try to read it from cover to cover. You won’t make it through. =) Instead, SP 800-60 is a reference to determine the criticality of systems using… wait for it… the BRM. As you might expect, it’s a good reference material like a government-wide data criticality dictionary. It level-sets the security expectations and definitions of what criticality is government-wide.

How do we use this thing? Well, the SP has a “stuffy” process description complete with phrases like “provisional impact level”, this is the Guerilla’s Guide to Data Categorization, so we’ll keep it simple:

• Take a business function.
• Locate it on the BRM. It might be in as many as 15 different places.
• Find the BRM section in 800-60.
• Read the description of the data, see if it fits what you’re looking for
• Look at the criticality description. Usually it’s a “fielder’s choice”: if the data matches <this description>, then it’s <this> critical, if it matches <this description>, then it’s <this> critical.
• Assign a criticality based on the 800-60 definitions.
• Use the “Common Sense Test”–does what you’ve assigned make sense? You might have other factors such as data aggregation that might make it worth more to you. Feel free to deviate.

So now, going back to my own private list of data types, let’s assign a criticality and a justification:

• Customer Mission Data–this inherits the criticality from what the customer says it is, which is usually MMM. But then again, I rate the criticality for my company and my business unit, which might be different from what the government thinks it’s worth.
• Security Incident Data–we own the systems that this data is on, but the government says that it’s high for criticality because they do not want to expose this data to the press until they’re ready and they have high integrity requirements so they can produce it as evidence and send the perpetrator to a “Federal Pound You .* Prison”. We segregated this data type from network monitoring and performance data because doing so means that we have a smaller pool/quantity of high-criticality data. Criticality is HHM.
• Internal Purchasing Data–usually LML criticality except for the SoX separation of duty for purchasing, etc. I don’t typically deal with this kind of data and rely on my company as a support vendor, so I have trace amounts under my control. Note that if your sole business is purchasing things for other people, this is probably MMH or thereabouts.
• IT Infrastructure Management Data–network monitoring data. Usually MML but inherits some criticality from the clients’ systems in that a monitoring system for a classified system is also classified even though it has trace amounts of mission data on it.
• Contracts Collateral Data–proposals and the like. This is MLL for CIA because we work with the government and most of it is public record but we still want to be able to keep our trade secrets secret if we’re working on a bid.
• Billing Data–MML. Our rates, where they came from, and the markup is for internal use only. It’s bad manners to show the customer your financial guts. =)
• HR Data–MML only because it contains private information that is the basis for data breach nightmares.

Notice what I didn’t explicitly state but I hinted around? You can have types of data that are covered under some regulation (yes, the infamous c*mpliance buzzwords). These can become data types in itself. For example, health information covered under HIPAA should be its own category of data.

Carrying this a bit further, I have my matrix which has the data types running down the left side with the following columns across the top:

• Criticality for client, corporation, and business unit
• Location of the data by IT system type (laptops, trouble ticket system, shared files, etc)
• Governing regulations (FISMA, NISPOM, Privacy Act, specific classifications)

Here, I think it’s hard to describe, I’ve posted it online for the world to see. I’ll add this into my “Book of Death” for the next revision. No, I didn’t spill the whole cookie jar, just give you a framework to build your own. If you want to pay me obscene amounts of money to come fill out a spreadsheet for you, I would be glad to, but you shouldn’t need that much help.

So what have we accomplished with this BRM exercise? Well, for a couple hours’ worth of work, I have the following things:

• A data criticality classification guide that I can hand to the security engineers to match up with security controls
• A security business impact assessment that I can hand to managers
• An azimuth check on which assets have the most value for us as a company
• A prioritization on who gets the biggest security budget
• A governance list to tell me which data types are governed by which regulations
• A list to exclude some assets from some types of regulations (ie, smaller scope means less audit when I have to pay for one)
• The start of a way to break down my enterprise into “bite-sized pieces”

And that’s a beautiful thing.

• In This Corner, the Business Reference Model
• New SP 800-60 is Out, Categorize Yerselves Mo Better
• Blow-By-Blow Commentary
• Another Day, Another Vendor
• Database Activity Monitoring for the Government

He’s a bit bloated but still remains the undeniable champion of business lines that the US Government operates. It’s the “business driver” of the Federal Enterprise Architecture. He’s the Business Reference Model and he’s not just for the federal-types to justify their existence. Let me explain….

The Business Reference Model is basically a hierarchy of all the functions that the US Government performs. The “short list” is the following:

• Services for Citizens
• Mode of Delivery
• Support of Delivery
• Management of Government Resources

And then underneath these broad headings is the fun things that we’re really interested in:

• User Fee Collection
• Contingency Planning
• IT Security
• Accounts Receivable

The BRM is fairly exhaustive so if you take any given government agency and what they do will fit somewhere on the chart. Every IT system I’ve seen fits somewhere, usually about 10 different places.

Now that we know how the government is supposed to work, I know what you’re thinking: how does this pass the “Dilligaf test?”

Well, to you and me, security dweebs at the core, a list of business functions means different types of information that each business activity needs. The BRM is in actuality a guide to the various data types that you’ll find throughout the government. When I say “Central Records and Statistics” what I really mean to say is “Data that supports Central Records and Statistics”.

But why do we care? We’re not the government, right? Well, we can take the same approach for a commercial enterprise.

Armed with this little bit of knowledge, I have my own business reference model and data types for what I do on a daily basis:

• Customer Mission Data
• Security Incident Data
• Internal Purchasing Data
• IT Infrastructure Management Data
• Contracts Collateral Data
• Billing Data
• HR Data

This started out as the “holy three”: customer data, contracts/collateral data, and NOC/SOC data. Then I expanded from there. You could just as easily start with something like this: purchasing, selling/marketing, and billing. Or maybe something like this: making money, spending money, and order fulfillment.

And then I have a matrix that says where this data is, here are some of the obvious locations:

• Corporate Email System
• Knowledge Management System
• Shared Directories
• Laptops
• Web Site
• Trouble Ticket System

Well, once you define what things you accomplish as a business, you can start to list where it’s at, or at least the majority of it. Occasionally you’ll get a shocker. =)

Coming up next: What you can do with BRM and Data Types and the fait accompli.

• And in This Corner, Special Publication 800-60
• New SP 800-60 is Out, Categorize Yerselves Mo Better
• Compensating Controls
• Blow-By-Blow Commentary
• DILLIGAF!!!

I bet nobody ever thought a System Security Plan would end up getting released to the world through a FOIA request.

Comments on the documents:

• The CI-100 DCS-3000 to EDMS System Security Plan is a little odd–why not just make it an interconnect document instead of a full SSP?  It’s just a strange way to manage things in my mind.
• The SSP, even though it’s from 2007, is way “old school”.  It doesn’t follow along the SP 800-53 catalog of controls that is pretty much down to a formula nowadays.  I guess the tech version is that the document has bit rot.
• The SSP details a technique to take a live feed of unclassified data and pump it into a classified system through a one-way serial cable (RS 232, remember what those are?)    =)   At any rate, it should be an interesting technique if you’re not used to dealing with that kind of interconnect.
• The Risk Assessment doesn’t describe what I would want to know, and that’s really the heart of my first comment.  Basically what I have is 2 systems that are connecting to each other, so what I want to know is what are the risks associated with each side and what is the risk of the interconnect itself.  Each side has their own security plan, so that’s why it’s an interconnect instead of a SSP.  But we haven’t addressed the security controls of the connection itself.
• There are some other minor annoyances, like “why are you grading the system on your ability to install ISS System Scanner” but I’ll leave those for you to go discover. =)

Have I jumped completely over the edge?  I think I have. =)

• One Catalog to Rule Them All
• Remembering Accreditation
• Feds to Embrace SaaS, End is Nigh for Security!
• Rebuilding C&A
• An Open Letter to NIST About SP 800-30