Well, this is a little bit of a departure from my usual random digital scribblings that I call a blog:  I partnered up with Vlad the Impaler and we created a slideshow complete with notes about why you should care about security and the Government and what you can learn from watching the Government succeed or fail.

The .pdf of the presentation is here.  Feel free to share with your friends, coworkers, and co-conspirators.

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• Archived for the World to See: SP 800-26
• The Accreditation Decision and the Authorizing Official
• When the Feds Come Calling
• Comments on SCAP 2008
• Massively Scaled Security Solutions for Massively Scaled IT

Ever watch a marathon on TV?  There’s the usual formula for how we lay out the day:

• History of the marathon and Pheidippides
• Discussion of the race length and how it was changes so that the Queen could watch the finish
• World records and what our chances are for making one today
• Graphics of the race course showing the key hills and the “sprint to the finish”
• Talk about the womens’ marathon including Joan Benoit and Kathrine Switzer
• Description of energy depletion and “The Wall”
• Stats as the leaders hit the finsh line
• Shots of “back-of-the-pack” runners and the race against yourself

Well, I now present to you the formula for FISMA Report Cards:

• Paragraph about how agencies are failing to secure their data, the report card says so
• History and trending of the report card
• Discussion on changing FISMA
• Quote from Karen Evans
• Quote from Alan Paller about how FISMA is a failure and checklist-driven security
• Wondering when the government will get their act together

Have a read of Dancho’s response to the FISMA Report Card.  Pretty typical writing formula that you’ll see from journalists.  I won’t even comment on the “FISMA compliance” title.  Oh wait, I just did.  =)

Some myths about FISMA in particular that I need to dispell right now:

1. FISMA is a report card:  It’s a law, the grades are just an awareness campaign.  In fact, the whole series of NIST Special Publications are just implementation techniques–they are guidance after all.  Usually the media and bloggers talk about what FISMA measures and um, well, it doesn’t measure anything, it just requires that agencies have security programs based on a short list of criteria such as security planning, contingency planning, and security testing.  It just goes back to the adage that nobody really knows what FISMA is.
2. FISMA needs to be changed:  As a law, FISMA is exactly where it needs to be.  Yes, Congress does have talks about modifying FISMA, but not much has come of it because what they eventually discover after much debate and sword-waving is that FISMA is the way to write the law about security, the problem is with the execution at all levels–OMB, GAO, and the agencies–and typically across organizational boundaries and competing master agendas.
3. There is a viable alternative framework:  Dancho points out this framework in his post which is really an auditors’ plugin to the existing NIST Framework for FISMA.  Thing is, nobody has a viable alternative framework because it’s still going to be the same people with the same training executing in the same environment.

Urban Cell-Phone Fire Myth photo by richardmasoner.  This myth is dispelled at snopes.com.

Way back last year I wrote a blog post about indicator species and how we’re expecting the metrics to go up based on our continual measuring of them.  Every couple of months I go back and review it to see if it’s still relevant.  And the answer this week is “yes”.

Now I’ve been thinking and talking probably too much about FISMA and the grades over the past couple of years, so occassionally I come to conclusions .  According to Mr Vlad the Impaler, the report card is a bad idea, but I’m slowly beginning to see the wisdom of it:  it’s an opportunity to have a debate and to raise some awareness of Government security outside of those of us who do it.  The only other time that we have a public debate about security is after a serious data breach, and that’s not a happy time.

I just wish the media would stop with the story line that FISMA is failing because the grades provide recursive evidence of it.

• FISMA Report Cards Issued–Response is Rote by Now
• GAO’s 5 Steps to “Fix” FISMA
• A Funny Thing Happened Last Week on Capital Hill
• Random Thoughts on “The FISMA Challenge” in eHealthcare
• When the Feds Come Calling

CAVEAT:  This document is dangerous!  See this post before you go any further.  You have been warned!

It stands to reason that one of my recurring search strings in my blog stats is people looking for a copy of NIST SP 800-26.  I even have commenters looking for it.  We like commenters enough to give them what they want, don’t we?

So I thought long and hard until my thinker was sore, asked some friends, and puzzled a bit more about why people would be so interested in a document that is, like Latin, dead.

My resident curmudgeon (yes, even a BSOFH needs a role model from time to time), Vlad the Impaler, offered up the suggestion:  That state and local governments need it because they’re usually 5-10 years behind the Federal Government.  Even then, I don’t get it, and with a shrug, I’ll leave it at that.

Anyway, I’ve uploaded the most recent version here (foo.pdf caveat applies).  I got the file in an email from Vlad, so he’s the one you should really thank.  In the spirit of complete irony, this file could become the #1 download for me. =)

CAVEAT:  This document is dangerous!  See this post before you go any further.  You have been warned!

• An Open Letter to NIST About SP 800-30
• SP 800-53A Now Finally Final
• Old Saint NIST: Ho Ho Hold on, what’s this?
• Why You Should Care About Security and the Government
• Some Comments on SP 800-39

I’ve said it a million times before:  I don’t care if you switch to $FooFramework, as long as you have the same people executing it with the same skillset, the results will be the same.  Last week and for the near-term, it’s a new bill to replicate the tenets of FISMA and the NIST framework thereof.

Last week, Representative Langevin introduced HR 5983, the “Homeland Security Network Defense and Accountability Act of 2008”.  Some press on the bill:

• Security Focus
• Committee on Homeland Security

Now the big question for me on this bill (and really, any proposed law) is this:  How does this provide anything above and beyond what is already required by FISMA, OMB policies, and NIST guidelines?  My short analysis:  Not much, and Rep Langevin is just “stirring the pot” with the big spoon of politics.

HR 5983 requires the following:

• Re-establishes the role and staffing requirements for the CIO, including network monitoring
• Testing the DHS networks using “attack-based” protocols
• IG audits and reporting
• Adding responsibility for contractor systems

Again, nothing new here that isn’t required already.  The only benefit to this bill that I see is that if it’s law, the Executive Branch has to request the funding in their budget request and Congress has to (maybe) fund it. It isn’t that DHS doesn’t have the in-house expertise–they own US-CERT.  It’s not that they have a lack of smart people–they own the Security Line of Business.  It’s that there are only so many hours in the day to get things done, and DHS has had lots of work since their creation in 2002.

A little bit of peeking behind the security kimono at DHS is in order.  DHS consists of subagencies, known as Operational Elements, such as TSA, ICE, CBP, etc.  The heads of these agencies are peers to the DHS CIO and have their own CIO and CISO, even though that’s not what they’re called.  See, the OEs do not have to listen to the DHS CIO, and that’s a huge problem.  Last year, DHS made the DHS CIO the budget approver for the OE’s IT budgets, which is a step forward, but still there is much room for improvement.  That’s something that Congress can fix.

Now it just isn’t a “Government IT Security News Day” without a comment from Alan Paller of SANS fame…

“One story is missing from this issue because the press hasn’t picked it up yet. Under Chairman Langevin of Rhode Island, the US House of Representatives Subcommittee on Emerging Threats and Cybersecurity just approved a new bill that changes how security will be measured, at least at the Department of Homeland Security. This is the beginning of the end of the huge waste under FISMA and the start of an era of continuous monitoring and automation. Long overdue. Look for news stories over the coming days.
Alan”

Like I say sometimes, I’m a bear of little brain and a recovering infantryman, but why is the answer to a law to make another law saying the same exactly the same thing.  All I have to say is this:  You’re not on Slashdot, you actually have to read the bill before you comment on it.  I didn’t see anything that supports what Alan’s saying.    =)

Capitol at Sunset by vgm8383.

To me, the very interesting thing about this bill is this provision:

“Before entering into or renewing a covered contract, the Secretary, acting through the Chief Information Officer, must determine that the contractor has an internal information systems security policy that complies with the Department’s information security requirements, including with regard to authentication, access control, risk management, intrusion detection and prevention, incident response, risk assessment, and remote access, and any other policies that the Secretary considers necessary to ensure the security of the Department’s information infrastructure.”

I have an issue with the language of this provision.  It’s one of scope.

But perhaps an explanation is in order.  Most (OK, mabye half or a little bit more, this isn’t a scientific number) government IT systems are contractor-operated.  These contractors have “Government data” on their corporate networks.  Some of this is fairly benign:  contracting collateral, statements of work, staffing plan, bill rates, etc.  Some of this is really bad:  PII, Privacy Act data, mission data, etc.  Some of this is “gray area”: trouble tickets, event data, SIEM data, etc.

Now taking this back to cost-effective, adequate security, what the Langevin bill means is that you’re taking the FISMA framework and applying it to all contractors without any bounds on what you consider within your realm of protection–ie, according to the language of the bill, if I’m any contractor supporting DHS in an outsourcing engagement, you can audit my network, whether or not it has Government data on it.  This is a problem because your oversight cuts into my margins and in some cases does not provide the Government with the desired level of security.

My response as a contractor is the following:

• Increase my rates to compensate for the cost of demonstrating compliance
• Do not bid DHS contracts
• Adopt a policy that says that DHS policies apply to the systems containing government mission data and meta-data
• Charge the Government at Time and Materials for any new requirements that they levy on you for mitigation

Unfortunately, this is a game that the Government will win at with respect to controlling the contractor’s network and lose at with respect to cost.

Good contractors understand the liability of having separation between Government data and their own network.  Back in my CISO role, that was the #1 rule–do not putGovernment data on the corporate network or “cross the streams” (Thanks, Vlad).  In fact, I wrote a whole chunk of blog posts last year about outsourcing, go check them out.  In fact, we would give to the customer anything that could be built in a dedicated mode specifically for them.  The dedicated network sections used the customer’s policy, procedures, standards, and they got to test them whenever they wanted.  In back of that was a shared piece for things that needed large economy of scale, like the STK 8500 and the NOC dashboards to put all the performance data on one screen.

Having said that, some data does need to cross over to the contractor’s network (or, even better, a separate management network) in order to provide economy of scale.  In our case, it was trouble tickets–in order to split field technicians across different contracts to keep them billable, the only cost-effective way to do this is to have tickets go into a shared system.  Any other solution costs the Government a ton of money because they would be paying for full-time field techs to be on-site doing nothing.

The problem is that our guidance on contractor systems is grossly outdated and highly naive.  The big book of rules that we are using for contractor security is NISPOM.  Unfortunately, NISPOM only applies to classified data, and we’re left with a huge gap when it comes to unclassified data.

What we need is the unclassified version of NISPOM.

The NIST answer is in section 2.4 of SP 800-53:

The assurance or confidence that the risk to the organization’s operations, assets, and individuals is at an acceptable level depends on the trust that the authorizing official places in the external service provider. In some cases, the level of trust is based on the amount of direct control the authorizing official is able to exert on the external service provider with regard to the employment of appropriate security controls necessary for the protection of the service and the evidence brought forth as to the effectiveness of those controls. The level of control is usually established by the terms and conditions of the contract or service-level agreement with the external service provider and can range from extensive (e.g., negotiating a contract or agreement that specifies detailed security control requirements for the provider) to very limited (e.g., using a contract or service-level agreement to obtain commodity services such as commercial telecommunications services).

Hmmm, in a classic ploy of stealing lines from my Guerilla CISO Bag-o-Tricks ™, NIST has said “Well, it depends”.  And yes, it depends, but how do you impement that when OMB dictates that what NIST says is THE standard?

• When the Feds Come Calling
• How to Not Let FISMA Become a Paperwork Exercise
• More on Georgia’s FISMA Reporting
• Comments on SCAP 2008
• Random Thoughts on “The FISMA Challenge” in eHealthcare

The US Army occassionally does things right.

Well, one of the things that they do right is training. Our training process for squad and above is mostly focused around the Observer-Controller (OC) and their value proposition (my MBA word for the day, TYVM). Whenever you are training, there is an OC tagging right along with you to assess what and why you are doing something and then make recommendations at the end.

 

Observer-Controllers hard at work, photo by David Axe

What an OC brings with them (aside from their 31337 BBQ Ski11z):

• Experience of having seen the same task done hundreds of times with various groups.
• A strong understanding of the doctrinally-correct way to do a task.
• Techniques to fill out where doctrine is not specific enough.
• Sometimes they have pre-written standard operating procedures that they will share with you.

What an OC will never do:

• Use you resources to support themselves.
• Own the solution space for you.
• Criticize you in front of your troops.
• Interfere with your ability to do your mission.

Hmmm, sounds like the things that a good auditor does.

Auditors are in a fantastic position to help the auditee because of the wide range of experience in how other companies have been doing the exact same thing that you are doing.  Point is, there is a level of collusion that needs to happen between the auditor and the auditee, and the extent of that collusion is really what we’re talking about when we start looking at Separation of Duties and similar things.

Over the years, auditors and auditees have had the nature of their relationship change numerous times. Around the time of Sarbanes-Oxley, the pendulum swung wildly the way of “no relationship no how” and now it’s slowly moving back to somewhere normal. Here’s a podcast with Michael Oxley talking about how auditors need to collude better with the auditee.  Disclaimer:  this is part of a series that is produced by my firm, but I had no part in this, Mkay?

Here in DC, we have a saying (Ok, I made it up my own self):  “Collusion is not just a technique, it’s THE technique.”  =)

• Split-Horizon Assessments and the Oversight Effect
• A Niche to a Niche is Still Hard to Staff
• FISMA Report Card News, Formulas, and 3 Myths
• Cloud Computing and the Government
• Some Comments on SP 800-39