…and I’m excited.  I’ll be talking on “Meta-Metrics: Building a Scorecard for the Evaluation of Security Management and Control Frameworks” which is an Idea I’ve been mulling over on how to “build a better rat race” or at least to consciously build security management frameworks in a coherent manner. Obviously I’ll put up slides afterwords.

Agenda is here, I think there is still time to sign up and come as long as you’re not going to be a wallflower.  =)

• Draft of SP 800-37 R1 is Out for Public Review
• Oh Lookie, Somebody’s Doing What I Said To Do….
• Federal Computer Week and S.773
• A New Take on Continuous Controls Monitoring
• CISOin’ Ain’t Easy, But It’s a Living

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

If it wasn’t frustrating dealing with the huge conflict-of-interest that follows the Government’s InfoSec pocketbook, it would be absolutely hilarious to watch the myriad interactions between all the competing interests at work, all with their grand plan on how to “fix” something that, in their opinion, is grossly broken.  Not that their idea is any better or will be executed better, it’s that it’s something new and gives them soundbites.

I’ll even admit to having my own opinions from time to time, although I’m not in it for the filthy lucre, just trying to help.  =)

• Preliminary Findings on Cybersecurity Review Now Out
• IKANHAZFIZMA and Transparency
• The InfoSec D-List and IKANHAZFIZMA
• Cyber-Workforce Training?
• Lolcats take on Laws, Sausage, Cyberwhatzits, and PCI

Fun things happened yesterday.  In case you hid under a rock, the Intertubes were rocking yesterday with the thudding of fingera on keyboard as I live-tweeted the Senate Homeland Committee’s hearing on “Protecting Cyberspace as a National Asset: Comprehensive Legislation for the 21st Century”.  And oh yeah, there’s a revised version of S.3474 that includes some of the concepts in S.773.  Short version is that the cybersecurity bills are going through the sausage factory known as Capitol Hill and the results are starting to look plausible.

You can go watch the video and read the written testimonies here.  This is mandatory if you’re working with FISMA, critical infrastructure, or large-scale incident response.  I do have to warn you, there are some antics afoot:

• Senator Collins goes all FUD on us.
• Senator McCain grills Phil Reitinger if DHS can actually execute a cybersecurity mission.
• Alan Paller gets all animated and opens up boxes of paperwork.  I am not amused.

• Blow-By-Blow on S.773–The Cybersecurity Act of 2009–Part 4
• Blow-By-Blow on S.773–The Cybersecurity Act of 2009–Part 2
• Blow-By-Blow on S.773–The Cybersecurity Act of 2009–Part 3
• In Response to “Cyber Security Coming to a Boil” Comments….
• Blow-By-Blow on S.773–The Cybersecurity Act of 2009–Part 5

Some days I feel like all this “continuous monitoring” talk around the beltway is just really a codeword for “buy our junk”, much like the old standby “defense in depth”, only instead of firewalls and IDS, it’s desktop and server configuration management.  Even better that it works for both products and services.  The BSOFH in me likes having a phrase like “Near Real-Time Continuous Compliance Monitoring” which can mean anything from “tying thermite grenades to the racks in case of being captured” to “I think I’ll make a ham sandwich for lunch and charge you for the privilege”.

Anyway, our IKANHAZFIZMA lolcats have finally found a control worth monitoring:  the world’s supply of overstuffed cheeseburgers.  This continuous monitoring thing is serious business, just like the Internets.

• Federal Computer Week and S.773
• Metricon is Next Week
• Oh Lookie, Somebody’s Doing What I Said To Do….
• CISOin’ Ain’t Easy, But It’s a Living
• Draft of SP 800-37 R1 is Out for Public Review

OK, since everybody seems to think that FISMA is some evil thing that needs reform, this is the version of events on “Planet Rybolov”:

Goals to surviving FISMA, based on all the criticisms I’ve read:

• Reduce paperwork requirements. Yes, some is needed.  Most is not.
• Reduce cost. There is much repetition in what we’re doing now, it borders on fraud, waste, and abuse.
• Increase technical effectiveness. IE, get from the procedural and managerial tasks and get down into the technical parts of security.

“Uphold our Values-Based Compliance Culture photo by kafka4prez.

So now, how do you keep from letting FISMA cripple you or turn into death-by-compliance:

• Prioritize. 25% of your controls need to not fail 100% of the time.  These are the ones that you test in-depth and more frequently.  Honestly, how often does your risk assessment policy get updated v/s your patch management?  Believe it or not, this is in SP 800-53R3 if you interpret it in the correct context.  More importantly, do not let your auditors dictate your priorities.
• Use common controls and shared infrastructure. Explicitly tell your system owners and ISSOs what you are providing as the agency CISO and/or the GSS that they are riding on.  As much as I hate meetings, if you own a General Support System (GSS), infrastructure (LAN/WAN, AD Forest, etc), or common controls (agency-wide policy, budget, Security Operations Center, etc), you have a fiduciary, legal, and moral obligation to get together with your constituency (the people who rely on the security you provide) and explain what it is you provide and allow them to tell you what additional support they need.
• Share Assessment Results. I’m talking about results from service providers with other agencies and systems.  We’re overtesting on the high-level stuff that doesn’t change and not on the detailed stuff that does change.  This is the nature of security assessments in that you start at the top and work your way down into the details, only most assessments don’t get down into the details because they’re busy reworking the top-level stuff over and over again.  Many years ago as a contractor managing infrastructure that multiple agencies used, it was unbelievably hard to get one agency to allow me to share security documents and assessment results with other agencies.  Shared assessment results mean that you can cut through the repetitious nature of what you’re doing and progressively get deeper into the technical, frequently-changing security aspects.
• Simplify the Paperwork. Yes, you still need to document what you’re doing, but the days of free-text prose and being graded on grammar and punctuation need to be over.  Do the controls section of System Security Plans as a Requirement Traceability Matrix.  More important than that, you need to go by-control by-component.  If you are hiring contractors and their job is to do copypasta directly from NIST documents and change the pronouns and tenses, you’re doing it wrong.  Don’t stand for that in your security policy or anything else that you do.
• Automate Wherever Possible. Note that the controls that change frequently and that need to not fail usually fit into this group.  It’s one of those “Things that make Rybolov go ‘Hmmmm'”.  Technology and automation provide both the problem and the solution.  Also see my first point up above.
• Fire 50% of Your Security Staff. Yes, I’m serious.  Those people you didn’t need anyway, primarily because they’re violating all the points I’ve made so far.  More importantly, 25 clueless people can mess things up faster than 5 clueful people can fix them, and that’s a problem for me.  Note that this does not apply to @csoandy, his headcount is A-OK.

The incredible thing to me is that this stuff is already there.  NIST writes “hooks” into their Special Publications to allow the smart people the room to do all these things.

And now the part where I hop up on my soapbox:  reforming FISMA by new legislation will not make any achievements above and beyond what we have today (with the exception of creating a CISO-esque position for the Exective Branch) because of the nature of audit and compliance.  In a public policy sense, the more items you have in legislation, the more the audit burden increases and the amount of repetition increases, and the amount of nonsense controls (ie, AntiVirus for Linux servers) increases.  Be careful what you ask for, you just might get it.

• “Machines Don’t Cause Risk, People Do!”
• Security Assessments as Fraud, Waste, and Abuse
• GAO’s 5 Steps to “Fix” FISMA
• When the Feds Come Calling
• Observations on SP 800-37R1