Contrary to what you might hear this week in the trade press, FedRAMP is not fully unveiled although there was some much-awaited progress. There was a memo that came out from the administration (PDF caveat).  Basically what it does is lay down the authority and responsibility for the Program Management Office and set some timelines.  This is good, and we needed it a year and a half ago.

However, people need to stop talking about how FedRAMP has solved all their problems because the entire program isn’t here yet.  Until you have a process document and a catalog of controls to evaluate, you don’t know how the program is going to help or hinder you, so all the press about it is speculation.

• Reinventing FedRAMP
• NIST Cloud Conference Recap
• An Open Letter to NIST About SP 800-30
• The Guerilla CISO Rants: Don’t Write a System Security Plan
• Clouds, FISMA, and the Lawyers

“Cloud computing is about gracefully losing control while maintaining accountability even if the operational responsibility falls upon one or more third parties.”
–CSA Security Guidance for Critical Areas of Focus in Cloud Computing V2.1

Now enter FedRAMP.  FedRAMP is a way to share Assessment and Authorization information for a cloud provider with its Government tenants.  In case you’re not “in the know”, you can go check out the draft process and supporting templates at FedRAMP.gov.  So far a good idea, and I really do support what’s going on with FedRAMP, except for somewhere along the lines we went astray because we tried to kluge doctrine that most people understand over the top of cloud computing which most people also don’t really understand.

I’ve already done my part to submit comments officially, I just want to put some ideas out there to keep the conversation going. As I see it, these are/should be the goals for FedRAMP:

• Delineation of responsibilities between cloud provider and cloud tenant.  Also knowing where there are gaps.
• Transparency in operations.  Understanding how the cloud provider does their security parts.
• Transparency in risk.  Know what you’re buying.
• Build maturity in cloud providers’ security program.
• Help cloud providers build a “Governmentized” security program.

So now for the juicy part, how I would do a “clean room” implementation of FedRAMP on Planet Rybolov, “All the Authorizing Officials are informed, the Auditors are helpful, and every ISSO is above average”?  This is my “short list” of how to get the job done:

• Authorization: Sorry, not going to happen on Planet Rybolov.  At least, authorization by FedRAMP, mostly because it’s a cheat for the tenant agencies–they should be making their own risk decisions based on risk, cost, and benefit.  Acceptance of risk is a tenant-specific thing based on the data types and missions being moved into the cloud, baseline security provided by the cloud provider, the security features of the products/services purchased, and the tenant’s specific configuration on all of the above.  However, FedRAMP can support that by helping the tenant agency by being a repository of information.
• 800-53 controls: A cloud service provider manages a set of common controls across all of their customers.  Really what the tenant needs to know is what is not provided by the cloud service provider.  A simple RACI matrix works here beautifully, as does the phrase “This control is not applicable because XXXXX is not present in the cloud infrastructure”.  This entire approach of “build one set of controls definitions for all clouds” does not really work because not all clouds and cloud service providers are the same, even if they’re the same deployment model.
• Tenant Responsibilities: Even though it’s in the controls matrix, there needs to be an Acceptable Use Policy for the cloud environment.  A message to providers: this is needed to keep you out of trouble because it limits the potential impacts to yourself and the other cloud tenants.  Good examples would be “Do not put classified data on my unclassified cloud”.
• Use Automation: CloudAudit is the “how” for FedRAMP.  It provides a structure to query a cloud (or the FedRAMP PMO) to find out compliance and security management information.  Using a tool, you could query for a specific control or get documents, policy statements, or even SCAP assessment content.
• Changing Responsibilities: Things change.  As a cloud provider matures, releases new products, or moves up and down the SPI stack ({Software|Platform|Infrastructure}as a Service), the balance of responsibilities change.  There needs to be a vehicle to disseminate these changes.  Normally in the IA world we do this with a Plan of Actions and Milestones but from the viewpoint of the cloud provider, this is more along the lines of a release schedule and/or roadmap.  Not that I’m personally signing up for this, but a quarterly/semi-annually tenant agency security meeting would be a good way to get this information out.

Then there is the special interest comment:  I’ve heard some rumblings (and read some articles, shame on you security industry press for republishing SANS press releases) about how FedRAMP would be better accomplished by using the 20 Critical Security Controls.  Honestly, this is far from the truth: a set of controls scoped to the modern enterprise (General Support System supporting end users) or project (Major Application) does not scale to an infrastructure-and-server cloud. While it might make sense to use 20 CSC in other places (agency-wide controls), please do your part to squash this idea of using it for cloud computing whenever and wherever you see it.

Ramp photo by ell brown.

• NIST Cloud Conference Recap
• Categories of Security Controls in Outsourcing
• FedRAMP: It’s Here but Not Yet Here
• Clouds, FISMA, and the Lawyers
• How to Not Let FISMA Become a Paperwork Exercise

Go check it out.  The project management folks have been jokingly grilled over numerous times for being ~2-3 months late.

However, comments are being accepted until December 2nd.  Do yourselves a favor and submit some comments.

• Reinventing FedRAMP
• Old Saint NIST: Ho Ho Hold on, what’s this?
• NIST Cloud Conference Recap
• A Funny Thing Happened Last Week on Capital Hill
• FedRAMP: It’s Here but Not Yet Here

Metricon 5 was this week, it was a blast you should have been there.

One of the things the program committee worked on was more of a practitioner focus.  I think the whole event was a good mix between theory and application and the overall blend was really, really good. Talking to the speakers before the event was much awesome as I could give them feedback on their talk proposal and then see how that conversation led to an awe-inspiring presentation.

I brought a couple security manager folks I know along with me and their opinion was that the event was way awesome. If you’re one of my blog readers and didn’t hunt me down and say hi, then whatcha waitin’ for, drop me an email and we’ll chat.

You can go check out the slides and papers at the Security Metrics site.

My slides are below.  I’m not sure if I was maybe a bit too far “out there” (I do that from time to time) but what I’m really looking for is a scorecard so that we can consciously build regulation and compliance frameworks instead of the way we’ve been doing it. This would help tremendously with public policy, industry self-regulation, and anybody who is trying to build their own framework.

• Massively Scaled Security Solutions for Massively Scaled IT
• Why We Need PCI-DSS to Survive
• DojoCon 2009 Presentation
• Building A Modern Security Policy For Social Media and Government
• Professor Rybolov’s Guide to InfoSec and Public Policy Analysis

Now I’ve been reasonably impressed with GovInfoSecurity.com and Eric Chabrow’s articles but this one supporting 20 CSC doesn’t make sense to me.  On one hand, you don’t have to treat your auditor’s word as gospel but on the other hand if we feed them what to say then suddenly it has merit?

Or is it just that all the security management frameworks suck and auditors remind us of that on a daily basis.  =)

However, it seems that there are 3 ways that people approach frameworks:

• From the Top–starting at the organization mission and working down the stack through policy, procedures, and then technology.  This is the approach taken by holistic frameworks like the NIST Risk Management Framework and ISO 27001/27002.  I think that if we start solely from this angle, then we end up with a massive case of analysis paralysis and policy created in a vacuum that is about as effective as it might sound.
• From the Bottom–starting with technology, then building procedures and policy where you need to.  This is the approach of the 20 Critical Security Controls.  When we start with this, we go all crazy buying bling and in 6 months it all implodes because it’s just not sustainable–you have no way to justify additional money or staff to operate the gear.
• And Then There’s Reality–what I really need is both approaches at the same time and I need it done a year ago. *sigh*

• SP 800-53A Now Finally Final
• Opportunity Costs and the 20 Critical Security Controls
• 20 Critical Security Controls: Control-by-Control
• A Niche to a Niche is Still Hard to Staff
• 20 Critical Security Controls: What They Did Right and What They Did Wrong

Going Off the Deep End

So I was thinking the other day (this is the part where people who know me in person usually go “oh cr*p”), partially spurred by a conversation I had with @csoandy and @secbarbie a couple of months ago.  I’ll get the idea out there: as an industry we need to embrace the concept of split-horizon assessments.

Two Purposes for Assessments

Because this is an insane approach that I’m just feeling out, let me go on a solo riff and explain what I’m talking about.  You see, I have two distinct purposes for getting a security assessment, both of which are in contention with each other:

• I want to fix my security by asking for money to fix the things that need attention.  When I get an assessment for this purpose, enumeration of my badness/suckness is good.  If I have a set of results that say that everything is great, then there’s no need for me to be given any more resources (time, money, people, gear).  Short-term, I’m fine, but what about my infrastructure-type long-term projects?  The net effect of a highly-scored annual assessment just might kill my program in 2 years as my funding and people are shifted elsewhere, especially in a .
• I want to keep my job and help my {company|agency|group} stay out of trouble by showing my zero-defects face and by demonstrating my due-diligence in protecting what has been given to me.  While the assessor has helped me short-term by identifying my problems and being a total hardass, if I’m not around in 6 months to adopt the recommendations into my security program, has the assessor actually helped me?

And this is the dilemma for just about every security manager out there.  One of the strategies is to alternate assessment types, but then your management wonder just what the heck it is you’re doing because you’re on top one year, then on the bottom the next.

Split Rock Lighthouse and Horizon photo by puliarf.

Assessor Window-Shopping

Now for the dirty little secret of the testing business:  there are really good testers who are the ninjas of the InfoSec world and there are really bad testers who don’t even validate their unlicensed Nessus scan.  I know, you’re shocked and it’s so blindingly obvious that Bruce Schneier will blog it 3 years from now.  =)

But there’s the part that you didn’t know:  security managers pick their assessor depending on the political mood inside their organization.  This is nowhere near a science, from what I’ve seen it involves a lot of navel-gazing on the part of the security team to see which is the lesser evil: having everybody think you’re incompetent or never getting anything new ever again?

Building a Better Rat Race

In order to accomplish both of the goals that I’ve listed, what I really need is a split-horizon assessment.  In other words, I need 2 reports from one assessment with different views for different audiences.  I know this sounds highly cynical, but it’s something we’ve been doing for some time now but just informally.  Might as well make it formal.

So are you sold on this concept yet?  In true form, I have an idea on how to get to a world of split-horizon assessments.  You can take any catalog of controls and divide it into “gotta have it” and “nice to have” (I almost divide these along the lines of “vulnerability mitigation” and “sustainable security program” or the “CISO” and “OMB and Congress”) buckets.  Then in your compliance assessment standard, require 2 reports for each assessment.  One is reported to the regulating authority and the other stays with the organization.

Indecision Strikes

I don’t know if I’ve solved the problemspace or not, but I’m looking for feedback “from the Peanut Gallery” so leave some comments.

• Security Assessment Economics
• Engagement Economics and Security Assessments
• Workin’ for the ‘Counters: an Analysis of my Love-Hate Relationship with the CPAs
• Security Assessments as Fraud, Waste, and Abuse
• A Funny Thing Happened Last Week on Capital Hill