So what exactly is a “system”?  After all this time, it’s still probably one of the most misunderstood ways that we manage security in the Government.

The short answer is this:  a system is what you say it is.  Long answer is it depends on the following factors:

• Maturity of your agency
• Budget processes and Exhibit 300s
• The extent of your common controls
• Political boundaries between inter-agency organizations
• Agency missions
• Amount of highly-regulated data such as PII or financial

Yes, this all gets complicated.  But really, whatever you say is a system is a system, the designation is just for you so you can manage the enterprise in pieces.  There are 3 main techniques that I use to determine what is a system:

• As a budget line-item: If it has an Exhibit 300, then it’s a system.  This works better for Plan of Actions and Milestones (POA&Ms) but in reality there might not be a 1:1 correllation between systems and Exhibit 300s.
• As a data type: If it has a particular type of data, then it’s a system.  This works well for special-purpose systems or where a type of data is regulated, such as PII or financial data.
• As a project or program: if it’s the same people that built it and maintain it, then it’s a system.  This dovetails in nicely with any kind of SDLC or with any kind of outsourcing.

Inventory photo by nutmeg.

Inventory management techniques that work:

• Less systems are better.  Each system incurs overhead in effort and cost.
• More systems works when you have no idea what is out there, but will cripple you in the long term because of the overhead.
• Start with many systems, assess each as its own piece, then consolidate them into a general support system or common controls package.
• Set a threshold for project size in either pieces of hardware or dollar value.  If the project exceeds that threshold, then it’s a system.
• Determine if something will be a system when the budget request is made.  Good CISOs realize this and have a place on the investment control board or capital planning investment board.

Guerilla CISO war story time:

Way back when all this was new, one of the agency CISOs would have a roundtable every quarter or so.  Won’t name who, but some of my blog readers do.  Almost every meeting devolved at some point into the time-honored sticking point of “what is a system?”  Everybody wanted to know if they had “2 servers, 3 PCs, a database, a dog, and a dickfore”, was that a system.  After one too many iterations, the gray-hair in the group would put up “Exhibit 300=System” on the whiteboard before every meeting.  Then when the inevitable conversation of “what is a system?” would come up, he would just point to the board.

And another story:

Several years ago I was working an IT outsourcing contract with an inventory that was determined using the budget line-item technique.  Turned out we had all sorts of systems, some of which didn’t make sense, like the desktop client to manage the local admin account.  One of my first priorities was to consolidate as many systems as I could.  Not that I was altruistic about saving money or anything, it was that the less systems I had, the less paperwork needed to be generated. =)   Most of the systems I rolled up into a general support system aimed at basic user connectivity.

• When the Feds Come Calling
• The Guerilla CISO Rants: Don’t Write a System Security Plan
• New SP 800-60 is Out, Categorize Yerselves Mo Better
• How Much Security Should the Outsourcer Do?
• Needed: Agency CSOs

This article at SC Magazine is exactly why.  Kudos to Dan Philpott for calling the author on his errors.

Things that go through my mind about articles like this:

• Is it that slow of a news day?  FISMA stuff is always good for a couple yucks when there’s nothing else to talk about.  Looks like somebody needed filler while everybody was flying to Black Hat and DefCon.
• Once again, we’re confusing FISMA the law with the implementation thereof.  Yawn.
• Ack, somebody who likes FDCC.  Actually, I like it too in theory, I just don’t like the implementation.
• “Government has influence when it comes to awareness and will have opportunities to use it.”  Um, yes, it’s the $75B IT budget, flex that muscle wherever you want to get the secure products you want.  Do not underestimate the power of the budget.
• Follow the FISMA Naysayer and spot somebody who’s looking for money.  In this case, it’s Fortify.

Funny thing is that I think I met the guy from Fortify a couple of months ago at a NoVa OWASP meeting for a showing of their fun-but-FUDtastic movie about application security.  You know, you’ve seen the trailer, it looked like this:

There is a way to influence thinking in this town, and writing trash articles like this is not the way to do it.  If Fortify really wants to change the world, I have some ideas on how to do it, but nobody ever asks.  =)

FUD Truck Makes a Delivery photo by crmudgen23.

Guerilla CISO story time:

About 9 months ago, I got a marketing packet from Borderware.  It said that “FooCorp is identified as sending spam” and offered me the opportunity to join their reputation service.

Looking at the materials they sent me, I deduced that none of the source IPs they listed was in our netblock and that what they were referring to was spam using @foocorp.com email addresses as the “from” address.  Um, not a whole lot you can do to stop that, although it does make for some fun abuse@ emails from users who don’t understand how spam works:  “Quit sending me this stuff, I’ll burn down your data center myself!!!111oneoneone”

Anyway, since the whole packet was pure FUD and not really relevant to anything I wanted to do, I sat down and sent an email to their Director of Marketing and CTO:

I know Borderware’s products, we use them in some of our solutions, and you have a good reputation.  Please don’t resort to such a lowbrow marketing scheme because it sullies your brand.

I think Fortify is in the same boat.  They have a good reputation–I have a friend who works for one of their biggest customers, and if he’s cool with it, I am.

But the question for all security companies remains:  how do I sell my product without resorting to spreading FUD everywhere I go?

• More Vendor Craziness
• No, FISMA Doesn’t Require That, Silly Product Pushers
• Comments on SCAP 2008
• Let’s Face it, Half the Security Industry is a Pyramid Scheme
• Splunk Goes After the FISMA Lucre, They’re not Alone

I toyed for several years about making an infosec hall of shame.  Like seriously, I already had some candidates, you know who most of them are, it’s the same as the Washington Post Front-Page Metric.

Hall of Fame, Hall of Shame photo by leafar.

And my friends and I had some other nummy tidbits from our travels out and about, doing this stuff in the place where theory meets the realities of implementation.

Now if you look around on The Guerilla CISO, you’ll find that I don’t have a Hall of Shame.  I eventually decided not to have one after much deliberation, and the reason is this:  If you have key decision-makers that are removed or abstracted from the impacts of the decisions that they make, it is not fair to publicly humiliate the people who have to live with the implementation of the decisions.

And for better or worse, that’s the way the Government’s security model (and many other things) works.

• An Informal Study on the Literacy Level of Security Blogs–We All Get Pwned by Amrit
• It’s a Blogiversary
• In Which Our Protagonist Discovers We Need More Good Public Policy People Who Understand Security
• Working with Interpreters, a Risk Manager’s Guide
• Federal CIO Council’s Guidelines on Security and Social Media

Article from William Jackson in Government Computer News:  Security policies remain a burden to federal IT managers, but they are producing results.

First off, GCN, come into the modern Web 2.0 era by letting people comment on your articles or at least allow trackbacks.  Having said that, let’s look at some of Mr Jackson’s points:

• NIST Special Publications: They’re good.  They’re free.  The only problem is that they’re burying us in them.  And oh yeah, SP 800-53A is finally final.
• Security and Vendors/Contractors:  It’s much harder than you might think.  If there’s interest, I’ll put out some presentations on it in my “copious amounts of free time”.  In the meantime, check out what I’ve said so far about outsourcing.
• Documentation and Paperwork:  Sadly, this is a fact of life for the Government.  The primary problem is the layers of oversight that the system owner and ISSO have.  When you are as heavily audited as the executive branch is, you tend to avoid risks and overdocument.  My personal theory is that the reason is insistence on compliance instead of risk management.
• Revising FISMA:  I’ve said it time and time again, the law is good and doesn’t need to be changed, the execution is the part that needs work.

• An Open Letter to NIST About SP 800-30
• FISMA Report Card News, Formulas, and 3 Myths
• Ooh, “The Word” is out on S 3474
• How to Not Let FISMA Become a Paperwork Exercise
• A Funny Thing Happened Last Week on Capital Hill

Check out this article by Andy Boots on the Tech Insiders blog.

It brings up an interesting point:  Agencies do not typically have a CSO-level manager.  According to FISMA, each agency has to have a CISO whose primary responsibility is information security.

But typically these CISOs do not have any authority over physical security or personnel security:  in reality, they work for the CIO and only have scope over what the CIO manages:  data centers, networks, servers, desktops, applications, and databases.

Except for one thing:  we’re giving today’s Government CISO a catalog of controls that contain physical and personnel security.  The “party line” that I’ve gotten from NIST is that the CISOs need to work through the CIO to effect change with the areas that are out of their control.  I personally think it’s a bunch of bull and that we’ve given CISOs all of the responsibility and none of the authority that they need to get the job done.  In my world, I call that a “scapegoat”.

To be honest, I think we’re doing a disservice to our CISOs, but the only way to fix it is to either move our existing CISOs out of the CIOs staff and make them true CxOs or write a law creating an agency CSO position just like Clinger-Cohen created the CIO and FISMA created the CISO.

• An Open Letter to NIST About SP 800-30
• Next Up in Security Legislation: S3474
• Opportunity Costs and the 20 Critical Security Controls
• Workin’ for the ‘Counters: an Analysis of my Love-Hate Relationship with the CPAs
• Database Activity Monitoring for the Government

Dear NIST People,

I have this semi-random digital scribbling thingie called a blog.  You might have heard of them.  Hey, you might have even at one point heard of mine.  =)

On my blog I let it be known that I am what the rest of the world would call a “NIST Cheerleader”.  I watch your every move.  I comment on your new publications.  I teach your framework every quarter.  From time to time, I criticize, but only because I have a foot in the theory of information security that you live and a foot in the implementation with agencies who know where the theory and models break.

The best thing that you have given us is not the risk management framework, it was SP 800-30, “Risk Management Guide for Information Systems”.  It’s small, to-the-point, and scalable from a single server to an entire IT enterprise.  Sure, the quants hate it, but for the quals and Government, it’s good enough.  I know private-sector organizations that use it.  One of my friends and blog readers/commenters was the guy who taught a group of people how to do risk assessment, then these same people went on to help you write the book.

I heard that you were in the process of revising SP 800-30.  While this is much needed to catch up/modernize, I want to make sure that 800-30 does not follow the “live by the catalog, die by the catalog” path that we seem to be following lately.  In other words, please don’t change risk assessment process to the following:

1. Determine boundary
2. Determine criticality
3. Conduct a gap assessment against a catalog of controls (SP 800-53/800-53A)
4. Attach a priority to mitigation
5. Perform risk avoidance because compliance models are yes/no frameworks
6. Document
7. ???
8. Profit!

At Your Own Risk Photo by  Mykl Roventine.

The reason that I am writing this is to let you know that I have noticed a disturbing trend in how now that we have a catalog of controls, the risk management framework is focusing more and more heavily on the catalog as the vehicle for determine an adequate level of security.  Some of this is good, some of this is not.

Why am I so concerned about this?  Well, inside the Government we have 2 conflicting ideas on information security:  compliance v/s risk management.  While we are fairly decent Government-wide at compliance management, the problem that we have is in risk management because risk management is only as good as the people who perform the risk assessment.  Not that we don’t have competent people, but the unknowns are what will make or break your security program, and the only way that you can known the unknowns is to get multiple assessments aimed at risks outside of the control catalog.

However, if you change the risk assessment process to a “catalog of controls gap analysis” process, then we’ve completely lost risk management in favor of compliance management.  To me, this is a disturbing trend that needs to be stopped.

Thank you for your time

–Rybolov

• Observations on SP 800-37R1
• Workin’ for the ‘Counters: an Analysis of my Love-Hate Relationship with the CPAs
• Reinventing FedRAMP
• It’s a Problem of Scale!
• Now ISC2 Blogs have an Opinion on FISMA