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

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

Rybolov’s note:  Vlad’s on a rant, at times like this it’s best sit back, read, and laugh at his curmudgeonly and snark-filled sense of humor.

So there I am having a beer at my favorite brew pub Dogfish Head Alehouse, in Fairfax, when my phone vibrates to this ditty…. I couldn’t get past the “breaking news.”

From: <The SANS Institute>

Sent: Friday, May 28, 2010 4:05 PM

To:Vlad_the_Impaler@myoldisp.net

Subject: SANS NewsBites Vol. 12 Num. 42 : House attaches FISMA corrections to Defense Authorization Bill for rapid action

* PGP Signed by an unmatched address: 5/28/2010 at 2:52:21 PM

Breaking News: US House of Representatives attaches new FISMA rewrite to Defense Authorization Bill. The press hasn’t picked it up yet, but NextGov.Com will have a story in a few minutes. This puts one more nail in the coffin of the Federal CISOs and security contractors who think they can go on ignoring OMB and go on wasting money on out of date report writing contracts.

Alan

Yet another millstone (pun intended) piece of legislation passed on a Friday with… a cheerleader?!?!??? Whoa.

This ruined what was turning out to be a decent Friday afternoon for me…

My beef is this — I guess I really don’t understand what motivates someone who vilifies Federal CISOs and security contractors in the same sentence? Does the writer believe that CISOs are in the pocket of contractors? Even I am not that much of a cynic… Which CISO’s are “ignoring OMB?” All of them except NASA? Are all of our Government CISOs so out of touch that they LIKE throwing scarce IT dollars away on “out of date report writing contracts?” (sic.) (Vlad – Are hyphens too costly?)

I could drop to an ad hominem attack against the writer, but that’s pretty much unnecessary and probably too easy. I’ll leave that to others.

Suffice to say that what is motivating this newsbit appears IMHO to be less about doing things the right way, and more about doing things their way while grabbing all the headlines and talking head interviews they possibly can. (See “self-licking Ice Cream Cone” in my last post)

Yeah, I’m a cynic. I’m a security professional. What’s yer point?

• Next Up in Security Legislation: S3474
• No, FISMA Doesn’t Require That, Silly Product Pushers
• Ooh, “The Word” is out on S 3474
• In Other News, I’m Saying “Nyet” on S.3474
• HR 5983–DHS Now Responsible for Contractor Security

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

Just a quick post to shill for Privacy Camp DC 2010 which will be taking place on the 17th of April in downtown DC.  I went last year and it was much fun.  The conversation ranged from recommendations for a rewrite of

The basic rundown of Privacy Camp is that it’s run like a Barcamp where the attendees are also the organizers and presenters.  If you’re tired of going to death-by-powerpoint, this is the place for you.  And it’s not just for government-types, there is a wide representation from non-profits and regular old commercial companies.

Anyway, what are you waiting for?  Go sign up now.

• Privacy Camp DC on June 20th
• In Response to “Cyber Security Coming to a Boil” Comments….
• Blow-By-Blow on S.773–The Cybersecurity Act of 2009–Part 3
• Blow-By-Blow on S.773–The Cybersecurity Act of 2009–Part 2
• Metricon 5 Wrapup

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