A few weeks back I read an article on an apparent shift in emphasis in government security… “OMB outlines shift on FISMA” take a moment to give it a read. I’ll wait….

That was followed by NASA’s “bold move” to change the way they manage risk…

Once again the over-emphasis and outright demagoguery on “compliance,” “FISMA reports,” “paper exercises,” and similar concepts that occupy our security geek thoughts have not given way to enlightenment. (At least “compliancy” wasn’t mentioned…) I was saddened by a return to the “FISMA BAD” school of thought so often espoused by the luminaries at SANS. Now NASA has leapt from the heights… At the risk of bashing Alan Paller yet again, I am often turned off by the approach of “being able to know the status of every machine at every minute, ” – as if machines by themselves cause bad security… It’s way too tactical (incorrect IMHO) and too easy to make that claim.

Hence the title of this rant – Machines don’t cause risk, people do!

The “people” I’m talking about are everyone from your agency director, down to the lowliest sysadmin… The problem? They may not be properly educated or lack the necessary skills for their position – another (excellent) point brought forth in the first article. Most importantly, even the most seasoned security veteran operating without a strategic vision within a comprehensive security program (trained people, budget, organizational will, technology and procedures) based upon the FISMA framework will be doomed to failure. Likewise, having all the “toys” in the world means nothing without a skilled labor force to operate them and analyze their output. (“He who dies with the most toys is still dead.”) Organizations and agency heads that do not develop and support a comprehensive security program that incorporates the NIST Risk Management Framework as well as the other facets listed above will FAIL. This is nothing new or revolutionary, except I don’t think we’ve really *done* FISMA yet. As I and others have said many times, it’s not about the paper, or the cost per page – it’s about the repeatable processes — and knowledgeable people — behind what the paper describes.

I also note the somewhat disingenuous mention of the risk management program at the State Department in the second article… As if that were all State was doing! What needs to be noted here is that State has approached security in the proper way, IMHO — from a Strategic, or Enterprise level. They have not thrown out the figurative baby with the bath water by dumping everything else in their security program in favor of the risk scoring system or some other bright, shiny object. I know first-hand from having worked with many elements in the diplomatic security hierarchy at State – these folks get it. They didn’t get to the current level of goodness in the program by decrying (dare I say whining about?) “paper.” They made the organizational commitment to providing contract vehicles for system owners to use to develop their security plans and document risk in Plans of Action and Milestones (POA&Ms). Then they provided the money to get it done. Is the State program a total “paragon of virtue?” Probably not, but the bottom line is that it’s an effective program.

Mammoth Strategy, Same as Last Year image by HikingArtist.com.

Desiring to know everything about everything may seem to some to be a worthy goal, but may be beyond many organization’s budgets. *Everything* is a point in time snapshot, no matter how many snapshots you take or how frequently you take them. Continuous, repeatable security processes followed by knowledgeable, responsible practitioners are what government needs. But you cannot develop these processes without starting from a larger, enterprise view. Successful organizations follow this–dare I say it–axiom whether discussing security governance, or system administration.

Government agencies need to concentrate on developing agency-wide security strategies that encompass, but do not concentrate on solely, what patch is on what machine, and what firewall has which policy. Likewise, system POA&Ms need to concentrate on higher-level strategic issues that affect agencies — things like changes to identity management schemes that will make working from home more practical and less risky for a larger percentage of the workforce. Or perhaps a dashboard system that provides the status of system authorization for the agency at-a-glance. “Burying your head in a foxhole” —becoming too tactical — is akin to burying it in the sand, or like getting lost in a bunch of trees that look like a forest. When organizations behave this way, everything becomes a threat, therefore they spray their resource firepower on the “threat of the day, or hour.”

An organization shouldn’t worry about patching servers if its perimeter security is non-existent. Developing the larger picture, while letting some bullets strike you, may allow you recognize threats, prioritize them, potentially allowing you to expend minimal resources to solve the largest problem. This approach is the one my organization is following today. It’s a crawl first, then walk, then run approach. It’s enabled management to identify, segregate, and protect critical information and resources while giving decision-makers solid information to make informed, risk-based decisions. We’ll get to the patches, but not until we’ve learned to crawl. Strangely, we don’t spend a lot of time or other organizational resources on “paper drills” — we’re actively performing security tasks, strategic and tactical that follow documented procedures, plans and workflows! Oh yes, there is the issue of scale. Sorry, I think over 250 sites in every country around the world, with over 62 different government customers tops most enterprises, government or otherwise, but then this isn’t about me or my organization’s accomplishments.

In my view, professional security education means providing at least two formal paths for security professionals – the one that SANS instantiates is excellent for administrators – i.e., folks operating on the tactical level. I believe we have these types of security practitioners in numbers. We currently lack sufficient seasoned professionals – inside government – who can approach security strategically, engaging agency management with plans that act both “globally” and “locally.” Folks like these exist in government but they are few. Many live in industry or the contractor space. Not even our intelligence community has a career path for security professionals! Government as a whole lacks a means to build competence in the security discipline. Somehow government agencies need to identify security up-and-comers within government and nurture them. What I’m calling for here is a government-sponsored internal mentorship program – having recognized winners in the security game mentor peers and subordinates.

Until we security practitioners can separate the hype from the facts, and can articulate these facts in terms management can understand and support, we will never get beyond the charlatans, headline grabbers and other “self-licking ice cream cones.” Some might even look upon this new, “bold initiative” by NASA as quitting at a game that’s seen by them as “too hard.” I doubt seriously that they tried to approach the problem using a non-academic, non-research approach. It needed to be said. Perhaps if the organization taking the “bold steps” were one that had succeeded at implementing the NIST guidance, there might be more followers, in greater numbers.

Perhaps it’s too hard because folks are merely staring at their organization’s navel and not looking at the larger picture?

Lastly, security needs to be approached strategically as well as tactically. As Sun Tzu said, “Tactics without strategy is the noise before defeat.”

• A Funny Thing Happened Last Week on Capital Hill
• How to Not Let FISMA Become a Paperwork Exercise
• When the Feds Come Calling
• Ooh, “The Word” is out on S 3474
• Some Comments on SP 800-39

As I’m going through a wide variety of control frameworks in a managed services/cloud environment, I’m reminded of how controls work when you’re a service provider.  Mentally, I break them down into four “buckets”:

• Controls that I provide to all customers as part of my baseline. In other words, these are things that I do for all of my customers because it’s either part of the way that I do business or it makes sense to do it once and scale it out to everybody.  Typically these are holistic information security program things (ISO 17799/27001/27002 or similar) matched up with my service-delivery architecture.
• Controls that I provide as an add-on service. Not all of my customers need these but I want to offer them to my customers to help them with their security program.  Usually these are services and products supporting a regulatory framework specific to one industry:  PCI-DSS, FISMA, GLBA, etc fit in here if my market is not exclusive to customers governed by those regulations.  In order to keep the base cost for the other customers low, these aren’t included in the base service but are available for a price.
• Controls that I am planning on building. I don’t have them yet but they’re on my roadmap.  Sometimes this is how I get into new markets by building the products and services that match up against the regulatory framework for that market, then build to that as a specification.
• Controls that I will not provide. Maybe this control doesn’t apply to my products and service (The “We don’t actually own a Windows/HP-UX/AIX server” problem).  Maybe the controls framework didn’t scope my solutions into its assumptions.  Maybe the economics of this didn’t work out.  Maybe I don’t provide this because it’s dishonest for both myself and you as my customer for me to say I provide this–think along the lines of accepting risk on your behalf which puts me into a conflict of interest.  This is why any vendor who says they provide 100% compliancy against FooFramework is lying.

Transparency ties it all together.  The good providers will tell you upfront which controls belong in which buckets.

Tool Bucket photo by tornatore.

• Reinventing FedRAMP
• Security Assessment Economics
• When the Feds Come Calling
• How to Not Let FISMA Become a Paperwork Exercise
• NIST Cloud Conference Recap

Sometimes it feels like auditing and oversight isn’t really the solution.  In fact, sometimes it feels like it’s part of the problem.  But when you’re sitting on Capitol Hill and your only tools are legislation, oversight, and auditing, you start to think that every problem can be solved with them. </soapbox>

• Senate Homeland Security Hearings and the Lieberman-Carper-Collins Bill
• Blow-By-Blow on S.773–The Cybersecurity Act of 2009–Part 5
• A Funny Thing Happened Last Week on Capital Hill
• Why We Need PCI-DSS to Survive
• In Other News, I’m Saying “Nyet” on S.3474

Well, several funny things happened, they happen every week.  But specifically I’m talking about the hearing in the House Committee on Homeland Security on FISMA reform–Federal Information Security: Current Challenges and Future Policy Considerations.  If you’re in information security and Government, you need to go read through the prepared statements and even watch the hearing.

Also referenced is HR.4900 which was introduced by Representative Watson as a modification to FISMA.  I also recommend that you have a look at it.

Now for my comments and rebuttals to the testimony:

• On the cost per sheet of FISMA compliance paper: If you buy into the State Department’s cost of $1700 per sheet, you’re absolutely daft.  The cost of a security program divided by the total number of sheets of paper is probably right.  In fact, if you do the security bits right, your cost per sheet will go up considerably because you’re doing much more security work while the volume of paperwork is reduced.
• Allocating budget for red teams: Do we really need penetration testing to prove that we have problems?  In Mike Smith’s world, we’re just not there yet, and proving that we’re not there is just an excuse to throw the InfoSec practitioners under the bus when they’re not the people who created the situation in the first place.
• Gus Guissanie: This guy is awesome and knows his stuff.  No, really, the guy is sharp.
• State Department Scanning: Hey, it almost seems like NIST has this in 800-53.  Oh wait, they do, only it’s given the same precedence as everything else.  More on this later.
• Technical Continuous Monitoring Tools: Does anybody else think that using products of FISMA (SCAP, CVE, CVSS) as evidence that FISMA is failing is a bit like dividing by zero?  We really have to be careful of this or we’ll destroy the universe.
• Number of Detected Attacks and Incidents as a Metric: Um, this always gets a “WTF?” from me.  Is the number increasing because we’re monitoring better or is it because we’re counting a whole bunch of small events as an attack (ie, IDS flagged on something), or is it because the amount of attacks are really increasing?  I asked this almost 2 years ago and nobody has answered it yet.
• The Limitations of GAO: GAO are just auditors.  Really, they depend on the agencies to not misrepresent facts and to give them an understanding of how their environment works.  Auditing and independent assessment is not the answer here because it’s not a fraud problem, it’s a resources and workforce development problem.
• OMB Metrics: I hardly ever talk bad about OMB, but their metrics suck.  Can you guys give me a call and I’ll give you some pointers?  Or rather, check out what I’ve already said about federated patch and vulnerability management then give me a call.

So now for Rybolov’s plan to fix FISMA:

1. You have to start with workforce management. This has been addressed numerous times and has a couple of different manifestations: DoDI 8570.10, contract clauses for levels of experience, role-based training, etc.  Until you have an adequate supply of clueful people to match the demand, you will continue to get subpar performance.
2. More testing will not help, it’s about execution. In the current culture, we believe that the more testing we do, the more likely the people being tested will be able to execute.  This is highly wrong and I’ve commented on it before.  I think that if it was really a fact of people being lazy or fraudulent then we would have fixed it by now.  My theory is that the problem is that we have too many wonks who know the law but not the tech and not enough techs that know the law.  In order to do the job, you need both.  This is also where I deviate from the SANS/20 Critical Security Controls approach and the IGs that love it.
3. Fix Plans of Actions and Milestones. These are supposed to be long-term/strategic problems, not the short-term/tactical application of patches–the tactical stuff should be automated.  The reasoning is that you use these plans for budget requests for the following years.
4. Fix the budget train. Right now the people with the budget (programs) are not the people running the IT and the security of it (CIO/CISO).  I don’t know if the answer here is a larger dedicated budget for CISO’s staff or a larger “CISO Tax” on all program budgets.  I could really policy-geek out on you here, just take my word for it that the people with the money are not the people protecting information and until you account for that, you will always have a problem.

Sights Around Capital Hill: Twice Sold Tales photo by brewbooks. Somehow seems fitting, I’ll let you figure out if there’s a connection. =)

• “Machines Don’t Cause Risk, People Do!”
• GAO’s 5 Steps to “Fix” FISMA
• How to Not Let FISMA Become a Paperwork Exercise
• In Other News, I’m Saying “Nyet” on S.3474
• The 10 CAG-egorically Wrong Ways to Introduce Standards

So by now NIST SP 800-37 R1 has made the rounds.  I want to take a couple of minutes to go over my theory on this update.

Summary of changes:

• Certification is gone.  Accreditation has now changed to “Authorization”.  This is interesting to me because it removes certification which I’ve always equated with compliance.
• There is more focus on continuous monitoring.
• NIST has made it more obvious that the process in 800-37 is the security aspects of a SDLC.
• There is much more more emphasis on enterprise-level controls.

So those of you out there who have been succeeding with the NIST Risk Management Framework  have been doing this all along, and it’s actually why you’ve succeeded.  For the rest of you, if you have to change your existing process, you’ve been doing it wrong.

Now for what’s missing and where you need to fill in the gaps:

• Prioritization of controls.  If everything is important, nothing is important.  You have to be able to determine which controls you need to succeed 100% of the time and which controls only need 75% reliability.  Hey, I even give credit to the SANS 20 Critical Security Controls, as flawed as they are, for this.
• Delineation of controls into shared/common, hybrid, and system-specific.  This is by design, it’s up to the departments and agencies to figure this out.  If you do this correctly, you save a ton of time and effort.  I remember the day my certifier told me that we didn’t recognize shared controls and that it was on me to provide evidence of controls that were provided at the enterprise–it still baffles me how you really expect one person on a project team to have the resources of the entire IT security staff.
• Continuous monitoring is up to you.  Along with prioritization, you have to determine which controls you need to monitor and a plan on how to do that.  Protip: these are usually technical controls that you can automate and should do so because it’s the only way to get the job done.
• Tailor, tailor, tailor.  It is not enough to use generic 800-53 controls.  It definitely is sub-par to use untailored 800-53A test procedures as your test plan.  These all depend on the implementation and need to be tailored to fit.

And finally, a shout-out to Dan Philpott at FISMAPedia.org.  Dan literally consumes new legislation, regulation, guidelines, and standards as they come out and annotates them with a wealth of analysis.

800-37 WordCloud by ME! Thanks to wordle.net for the tool to make it.

• SP 800-53A Now Finally Final
• NIST Cloud Conference Recap
• Special Publication 800-53 Revision 3 Workshop
• How to Not Let FISMA Become a Paperwork Exercise
• Some Comments on SP 800-39

Part 1

Part 2

Takeaways from the 20 CSC and what they do right (hey, it’s not all bad):

You have to prioritize. On a system basis, there are maybe 50-60 800-53 controls (out of a number just shy of 200) that need to be built 100% correctly and working every single time.  The rest (I know, I’m putting on my heretic hat here) can lapse from time to time.  For example, if I don’t have good event monitoring, my incident response team doesn’t have much work because I don’t know if I’m pwned or not.  What 20 CSC does is try to reduce that set of stuff that I should be concerned about into a set of controls that are technical, tactical, and track to classes taught by SANS vulnerability-based .

Common controls are more important than ever. They help you scope the smaller systems.  In fact, roughly half of the 20 CSC apply to the modern Enterprise and should be absorbed there, meaning that for systems not owning infrastructure, we only have 10 or so controls that I have to worry a bunch about, and 10 that I just need to be aware of what’s provided by my CISO.

Give examples. I’ll even go as far as to say this:  it should be a capital offense to release a catalog of controls without a reference implementation for both an Enterprise/GSS and a smaller IT system/Major Application inside of it.  20 CSC stops maybe one step short of that, but it’s pretty close in some controls to what I want if they were structured differently.

Security Management v/s IT Management. IT asset inventory, configuration management, change control:  these are IT management activities that somehow get pushed onto the security team because we are more serious about them than the people who should care.  I think 20 CSC does an OK job of just picking out the pieces that apply to security people instead of the “full meal deal” that ITIL and its ilk bring.

Control Key photo by .faramarz.

Now for what they did wrong:

It’s Still Not a Consensus, Dammit! That is, it’s a couple of smart people making a standard in a vacuum and detached from the folks who will have to live by the work that they do.  Seriously, ask around inside the agencies:  who admits to helping develop 20 CSC aside from “yeah, we looked at it briefly”?  And I’m not talking about the list that SANS claims, that’s stripped from the bios of the handful of people who did work on 20 CSC.  Sadly, this is the quick path to fail, it’s like building an IT system without asking the users what they need to get their job done on a daily basis.  Guys, we should know better than this.

It’s Still Not a Standard. It’s still written as guidance–more anecdote than hard requirements.  This isn’t something I can put into a contract and have my contractors execute without modifying it heavily.  It’s also not official, something I’ve already touched on before, which means that it’s not mandatory.  If you want to make this a standard, you need to turn it into ~50 controls each written as a “contracting shall”.  More to come on this in the future.

It Has Horrible Metrics. And I’m talking really horrible…it’s like the goatse of security metrics (NSFW link, even though it’s wikipedia).  Why?  Because they’re time-based for controls that are not time-based.  Metrics need to be a way to evaluate that the control works, not the indirect effects of the control.  Of course, metrics are just a number, but at the end of whatever assessment, my auditor/IG/GAO/$foo has to come up with some way to rank the work that I’ve done as a security officer.  If 20 CSC is the vehicle for the audit and the metrics are hosed, it doesn’t matter what I can do to provide real security, the perception from my management is that I don’t know what I’m doing.

• 20 Critical Security Controls: Control-by-Control
• Opportunity Costs and the 20 Critical Security Controls
• The Guerilla CISO Rants: Don’t Write a System Security Plan
• Federated Vulnerability Management
• How to Not Let FISMA Become a Paperwork Exercise