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

So while I was at some conferences over the past couple of months, I had an awesome idea while sitting in a panel about data breaches, especially notification. While streaming conferences is pretty awesome for most content, I keep thinking that we need that as an industry we need the exact opposite: a track of the conference that is completely off-the-record.

Here in DC when we do smaller training sessions, we invoke the Chatham House Rule.  That is, the discussion is for non-attribution.  There are several reasons behind this:

• You don’t have to worry (too much, anyway) about vendors in attendance selling you something
• It won’t end up in the press
• It gets real information to people instead of things that are “fit for public consumption”

My local area has a hackers association (No linkie, if you have minimal skill you can find it) that meets to talk about mostly technical stuff and what folks are working on.  I find that more and more often when I do a talk there I do it “Off the Record” for a wide variety of reasons:

• I don’t want the attackers to get more effective
• I have half-baked ideas where I want/need feedback on if they are completely off-base
• The subject matter is in a legal gray-area and I’m not a lawyer
• I talk “on the record” all day every day about the same things
• I can “test-drive” presentation material to see how it works
• I can show nuts and bolts

So, the point of all this is that maybe we need to start having more frank discussions about what the bad guys are doing “in the wild” if we want to stop them, and that involves talking with peers from other companies inside the same industry to see what they are getting hit with.

Chatham House Rule photo by markhillary.

• Massively Scaled Security Solutions for Massively Scaled IT
• Metricon 5 Wrapup
• Civilians Ask “What’s With All the Privacy Act Kerfluffle?”
• Privacy Camp DC on June 20th
• Where is Rybolov?

OK, it’s been out a couple of months now with the usual “ZOMG it’s RealID all over again” worry-mongers raising their heads.

So we’re going to go through what NSTIC is and isn’t and some “colorful” (or “off-color” depending on your opinion) use cases for how I would (hypothetically, of course) use an Identity Provider under NSTIC.

The Future Looks Oddly Like the Past

There are already identity providers out there doing part of NSTIC: Google Authenticator, Microsoft Passport, FaceBook Connect, even OpenID fits into part of the ecosystem.  My first reaction after reading the NSTIC plan was that the Government was letting the pioneers in the online identity space take all the arrows and then swoop in to save the day with a standardized plan for the providers to do what they’ve been doing all along and to give them some compatibility.  I was partially right, NSTIC is the Government looking at what already exists out in the market and helping to grow those capabilities by providing some support as far as standardizations and community management.  And that’s the plan all along, but it makes sense: would you rather have experts build the basic system and then have the Government adopt the core pieces as the technology standard or would you like to have the Government clean-room a standard and a certification scheme and push it out there for people to use?

Not RealID Not RealID Not RealID

Many people think that NSTIC is RealID by another name.  Aaron Titus did a pretty good job at debunking some of these hasty conclusions.  The interesting thing about NSTIC for me is that the users can pick which identity or persona that they use for a particular use.  In that sense, it actually gives the public a better set of tools for determining how they are represented online and ways to keep these personas separate.  For those of you who haven’t seen some of the organizations that were consulted on NSTIC, their numbers include the EFF and the Center for Democracy and Technology (BTW, donate some money to both of them, please).  A primary goal of NSTIC is to help website owners verify that their users are who they say they are and yet give users a set of privacy controls.

Stick in the Mud photo by jurvetson.

Now on to the use cases, I hope you like them:

I have a computer at home.  I go to many websites where I have my public persona, Rybolov the Hero, the Defender of all Things Good and Just.  That’s the identity that I use to log into my official FaceBook account, use teh Twitters, log into LinkedIn–basically any social networking and blog stuff where I want people to think I’m a good guy.

Then I use a separate, non-publicized NSTIC identity to do all of my online banking.  That way, if somebody manages to “gank” one of my social networking accounts, they don’t get any money from me.  If I want to get really paranoid, I can use a separate NSTIC ID for each account.

At night, I go creeping around trolling on the Intertubes.  Because I don’t want my “Dudley Do-Right” persona to be sullied by my dark, emoting, impish underbelly or to get an identity “pwned” that gives access to my bank accounts, I use the “Rybolov the Troll” NSTIC  ID.  Or hey, I go without using a NSTIC ID at all.  Or I use an identity from an identity provider in a region *cough Europe cough* that has stronger privacy regulations and is a couple of jurisdiction hops away but is still compatible with NSTIC-enabled sites because of standards.

Keys to Success for NSTIC:

Internet users have a choice: You pick how you present yourself to the site.

Website owners have a choice: You pick the NSTIC ID providers that you support.

Standards: NIST just formalizes and adopts the existing standards so that they’re not controlled by one party.  They use the word “ecosystem” in the NSTIC description a lot for a reason.

• Bacn–It’s Cooked Spam
• NIST Cloud Conference Recap
• LOLCATS and NSTIC
• When Standards Aren’t Good Enough
• More on Georgia’s FISMA Reporting

Ref: NSTIC
Ref: On the Internet…

• Realistic NSTIC
• Et Tu, TIC?
• Hackers, Protesters, Iran, Twitter, and Lolcats
• Cyberlolcats Watch the Hackers at DefCon
• LOLCATS and Hackable Coffee Pots

“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