Rybolov Note: this is such a long blog post that I’m breaking it down into parts.  Go read the bill here.  Go read part two here.  Go read part three here. Go read part four here.  Go read part 5 here. =)

So the Library of Congress finally got S.773 up on http://thomas.loc.gov/.  For those of you who have been hiding under a rock, this is the Cybersecurity Act of 2009 and is a bill introduced by Senators Rockefeller and Snowe and, depending on your political slant, will allow us to “sock it to the hackers and send them to a federal pound-you-in-the-***-prison” or “vastly erode our civil liberties”.

A little bit of pre-reading is in order:

• Chairman Rockefeller and Senator Snowe Introduce Comprehensive Cybersecurity Legislation
• Bill Press Release
• Will The Cybersecurity Act of 2009 Require IT Security Professionals To Get A License From The Feds?
• CADNA Supports the Introduction of the Cybersecurity Act of 2009
• http://www.eff.org/deeplinks/2009/04/cybersecurity-act
• Should Obama Control the Internet?

Timing: Now let’s talk about the timing of this bill.  There is the 60-day Cybersecurity Review that is supposed to be coming out Real Soon Now (TM).  This bill is an attempt by Congress to head it off at the pass.

Rumor mill says that not only will the Cybersecurity Review be unveiled at RSA (possible, but strange) and that it won’t bring anything new to the debate (more possibly, but then again, nothing’s really new, we’ve known about this stuff for at least a decade).

Overall Comments:

This bill is big.  It really is an omnibus Cybersecurity Act and has just about everything you could want and more.  There’s a fun way of doing things in the Government, and it goes something like this: ask for 300% of what you need so that you will end up with 80%.  And I see this bill is taking this approach to heart.

Pennsylvania Ave – Old Post Office to the Capitol at Night photo by wyntuition.

And now for the good, bad, and ugly:

SEC. 2. FINDINGS. This section is primarily a summary of testimony that has been delivered over the past couple of years.  It really serves as justification for the rest of the bill.  It is a little bit on the FUD side of things (as in “omigod, they put ‘Cyber-Katrina‘ in a piece of legislation”), but overall it’s pretty balanced and what you would expect for a bill.  Bottom line here is that we depend on our data and the networks that carry it.  Even if you don’t believe in Cyberwar (I don’t really believe in Cyberwar unles it’s just one facet of combined arms warfare), you can probably agree that the costs of insecurity on a macroeconomic scale need to be looked at and defended against, and our dependency on the data and networks is only going to increase.

No self-respecting security practitioner will like this section, but politicians will eat it up.  Relax, guys, you’re not the intended audience.

Verdict: Might as well keep this in there, it’s plot development without any requirements.

SEC. 3. CYBERSECURITY ADVISORY PANEL. This section creates a Cybersecurity Advisory Panel made up of Federal Government, private sector, academia, and state and local government.  This is pretty typical so far.  The interesting thing to me is “(7) whether societal and civil liberty concerns are adequately addressed”… in other words, are we balancing security with citizens’, corporations’, and states’ rights?  More to come on this further down in the bill.

Verdict: Will bring a minimal cost in Government terms.  I’m very hesitant to create new committees.  But yeah, this can stay.

SEC. 4. REAL-TIME CYBERSECURITY DASHBOARD. This section is very interesting to me.  On one hand, it’s what we do at the enterprise level for most companies.  On the other hand, this is specific to the Commerce Department –“Federal Government information systems and networks managed by the Department of Commerce.”  The first reading of this is the internal networks that are internal to Commerce, but then why is this not handed down to all agencies?  I puzzled on this and did some research until I remembered that Commerce, through NTIA, runs DNS, and Section 8 contains a review of the DNS contracts.

Verdict: I think this section needs a little bit of rewording so that the scope is clearer, but sure, a dashboard is pretty benign, it’s the implied tasks to make a dashboard function (ie, proper management of IT resources and IT security) that are going to be the hard parts.  Rescope the dashboard and explicitly say what kind of information it needs to address and who should receive it.

SEC. 5. STATE AND REGIONAL CYBERSECURITY ENHANCEMENT PROGRAM. This section calls for Regional Cybersecurity Centers, something along the lines of what we call “Centers of Excellence” in the private sector.  This section is interesting to me, mostly because of how vague it seemed the first time I read it, but the more times I look at it, I go “yeah, that’s actually a good idea”.  What this section tries to do is to bridge the gap between the standards world that is NIST and the people outside of the beltway–the “end-users” of the security frameworks, standards, tools, methodologies, what-the-heck-ever-you-want-to-call-them.  Another interesting thing about this is that while the proponent department is Commerce, NIST is part of Commerce, so it’s not as left-field as you might think.

Verdict: While I think this section is going to take a long time to come to fruition (5+ years before any impact is seen), I see that Regional Cybersecurity Centers, if properly funded and executed, can have a very significant impact on the rest of the country.  It needs to happen, only I don’t know what the cost is going to be, and that’s the part that scares me.

SEC. 6. NIST STANDARDS DEVELOPMENT AND COMPLIANCE. This is good.  Basically this section provides a mandate for NIST to develop a series of standards.  Some of these have been sitting around for some time in various incarnations, I doubt that anyone would disagree that these need to be done.

1. CYBERSECURITY METRICS RESEARCH:  Good stuff.  Yes, this needs help.  NIST are the people to do this kind of research.
2. SECURITY CONTROLS:  Already existing in SP 800-53.  Depending on interpretation, this changes the scope and language of the catalog of controls to non-Federal IT systems, or possibly a fork of the controls catalog.
3. SOFTWARE SECURITY:  I guess if it’s in a law, it has come of age.  This is one of the things that NIST has wanted to do for some time but they haven’t had the manpower to get involved in this space.
4. SOFTWARE CONFIGURATION SPECIFICATION LANGUAGE: Part of SCAP.  The standard is there, it just needs to be extended to various pieces of software.
5. STANDARD SOFTWARE CONFIGURATION:  This is the NIST configuration checklist program ala SP 800-70.  I think NIST ran short on manpower for this also and resorted back to pointing at the DISA STIGS and FDCC.  This so needs further development into a uniform set of standards and then, here’s the key, rolled back upstream to the software vendors so they ship their product pre-configured.
6. VULNERABILITY SPECIFICATION LANGUAGE: Sounds like SCAP.

Now for the “gotchas”:

(d) COMPLIANCE ENFORCEMENT- The Director shall–

(1) enforce compliance with the standards developed by the Institute under this section by software manufacturers, distributors, and vendors; and

(2) shall require each Federal agency, and each operator of an information system or network designated by the President as a critical infrastructure information system or network, periodically to demonstrate compliance with the standards established under this section.

This section basically does 2 things:

• Mandates compliancy for vendors and distributors with the NIST standards listed above.  Suprised this hasn’t been talked about elsewhere.  This clause suffers from scope problems because if you interpret it BSOFH-stylie, you can take it to mean that anybody who sells a product, regardless of who’s buying, has to sell a securely-configured version.  IE, I can’t sell XP to blue-haired grandmothers unless I have something like an FDCC variant installed on it.  I mostly agree with this in the security sense but it’s a serious culture shift in the practical sense.
• Mandates an auditing scheme for Federal agencies and critical infrastructure.  Everybody’s talked about this, saying that since designation of critical infrastructure is not defined, this is left at the discretion of the Executive Branch.  This isn’t as wild-west as the bill’s opponents want it to seem, there is a ton of groundwork layed out in HSPD-7.  But yeah, HSPD-7 is an executive directive and can be changed “at the whim” of the President.  And yes, this is auditing by Commerce, which has some issues in that Commerce is not equipped to deal with IT security auditing.  More on this in a later post.

Verdict: The standard part is already happening today, this section just codifies it and justify’s NIST’s research.  Don’t task Commerce with enforcement of NIST standards, it leads down all sorts of inappropriate roads.

• 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
• Blow-By-Blow on S.773–The Cybersecurity Act of 2009–Part 5
• Blow-By-Blow on S.773–The Cybersecurity Act of 2009–Part 4
• The World Asks: is S.773 Censorship?

Rybolov’s comment: This is Ian’s response to the comments for his post on Cybersecurity Coming to a Boil.  It was such a good dialog that he wanted to make a large comment which as we all know, eventually transforms itself into a blog post.  =)

You are making some excellent points; putting the leadership of the Administration’s new Cyber security initiative directly in the White House might appear to be a temporary solution or a quick fix. From my point of view, it looks more like an honest approach. By that I mean that I think the Administration is acknowledging a few things:

• This is a significant problem
• There is no coherent approach across the government
• There is no clear leadership or authority to act on the issue across the government
• Because of the perception that a large budget commitment will have to be allocated to any effective solution, many Agencies are claiming leadership or competing for leadership to scoop up those resources
• The Administration does not know what the specific solution they are proposing is — YET

I think this last point is the most important and is driving the 60-day security assessment. I also think that assessment is much more complex than a simple review of FISMA scores for the past few years. I suspect that the 60-day review is also considering things like legal mandates and authorities for various aspects of Cyber security on a National level. If that is the case, I’m not familiar with a similar review ever having taken place.

2004 World Cyber Games photo by jurvetson.  Contrary to what the LiquidMatrix Security folks might think, the purpose of this post isn’t to jam “cyber” into every 5th word.  =)

So, where does this take us? Well, I think we will see the Cyber Security Czar, propose a unified policy, a unified approach and probably some basic enabling legislation. I suspect that this will mean that the Czar will have direct control over existing programs and resources. I think the Cyber Security Czar taking control of Cyber Security-related research programs will be one of the most visible first steps toward establishing central control.

From this we will see new organizational and reporting authorities that will span existing Agencies. I think we can also anticipate that we will see new policies put in place and a new set of guidelines of minimum level of security capabilities mandated for all Agency networks (raising bottom-line security). This last point will probably prove to be the most trying or contentious effort within the existing Agency structure. It is not clear how existing Agencies that are clearly underfunding or under supporting Cyber Security will be assessed. It is even less clear where remedial funding or personnel positions will come from. And the stickiest point of all is…. how do you reform the leadership and policy in those Agencies to positively change their security culture? I noticed that someone used the C-word in response to my initial comments. This goes way beyond compliance. In the case of some Federal Agencies and perhaps some industries we may be talking about a complete change sea-change with respect to the emphasis and priority given to Cyber Security.

These are all difficult issues. And I believe the Administration will address them one step at a time.
In the long-term it is less clear how Cyber Security will be managed. The so-called war on drugs has been managed by central authority directly from the White House for decades. And to be sure, to put a working national system together that protects our Government and critical national infrastructure from Cyber attack will probably take a similar level of effort and perhaps require a similar long-term commitment. Let’s just hope that it is better thought-out and more effective than the so-called war on drugs.

Vlad’s point concerning Intelligence Community taking the lead with respect to Cyber Security is an interesting one, I think the Intelligence Community will be important players in this new initiative. To be frank, between the Defense and Intelligence Communities there is considerable technical expertise that will be sorely needed. However, for legal reasons, there are real limits as to what the Intelligence and Defense Communities can do in many situations. This is a parallel problem to the Cyber Security as a Law Enforcement problem. The “solution” will clearly involve a variety of players each with their own expertise and authorities. And while I am not anticipating that Tom Clancy will be appointed the Cyber Security Czar any time soon. I do expect that a long-term approach will require the stand-up of either a new organization empowered to act across current legal boundaries (that will require new legislation), or a new coordinating organization like the Counter Terrorism Center, that will allow all of the current players bring their individual strengths and authorities to focus on a situation on a case by case basis as they are needed (that may require new legislation).

If you press me, I think a joint coordinating body will be the preferred choice of the Administration. Everyone likes the idea of everyone working and playing well together. And, that option also sounds a lot less expensive. And that is important in today’s economic climate.

• Cyber Security coming to a boil
• Beware the Cyber-Katrina!
• Blow-By-Blow on S.773–The Cybersecurity Act of 2009–Part 4
• Et Tu, TIC?
• The 10 CAG-egorically Wrong Ways to Introduce Standards

During his campaign, then candidate Obama promised he would, “make cyber-security the top priority that it should be in the 21st century. I’ll declare our cyber-infrastructure a strategic asset, and appoint a national cyber-adviser, who will report directly to me.” Since Obama was elected there has been a great deal of speculation as to what real-life changes in direction and policy that promise would bring.

Last month, President Obama appointed Melissa Hathaway to be a Senior Director of the National Security Council. She immediately launched a 60-day review of security of Federal IT systems. As a result of this effort, there is much speculation that at the end of the 60-day review she will be appointed the National Cyber Advisor–the so-called Cyber Security Czar.

Just this week, the Director of the National Cyber Security Center, Rod A. Beckstrom, over at the Department of Homeland Security resigned. The press reports of Beckstrom’s resignation indicate some frustration on Beckstrom’s part. His frustration seems to be primarily aimed at the National Security Agency (NSA). Beckstrom suggests that the NSA has been subverting his efforts to coordinate cyber security efforts across the intelligence community.

A good friend of mine has suggested that the resignation is simply political and an artifact of the transition from one administration to another. He further suggests that this also signals a shift from leadership in cyber security from civilian agencies toward the Intelligence Community taking its turn at leadership. I think he may be right, too. However, I think there is more history here than just a shift in policy from one administration to another.

In my opinion, this isn’t just about politics. There are two drivers for this move. First, congress and the administration recognize that that the on-going assault on government and commercial networks is a national security issue and an economic security and competitiveness issue too. In today’s economic droop people often forget that two of our greatest economic strengths are our accumulated intellectual property and our hard working human capital. Both of these assests are discounted when criminal and national groups successfully attack our nations IT infrastructure. Recognizing this is a good thing, I’m not going to recount the long history of cyber assault on Federal IT systems by international cyber criminals, and “state-sponsored entities.” Facts and figures concerning this on-going assault and the damage associated with it is just a Google search away.

The second driver for a policy shift is that congress and the administration recognize that the FBI, Justice, DHS approach to cyber security is an utter failure. This failed approach sees cyber security as a criminal problem with industry participating in its own defense on a ‘voluntary’ basis. This has led to comical activities such as FBI delegation going to Moscow with hat in hand asking the Russians for help in tracking down successful Cyber Organized Crime groups based in Russia. The fact that these groups may have had strong official or unofficial connections with the Russian government should have given the FBI an indication of the lack of cooperation they would face –- I believe in Law Enforcement circles this is usually called a “clue”. Likewise, FBI delegations to Russia trying to track down Russian Cyber attackers that may have had some direct level of state support were equally unproductive. To be fair, the FBI was placed in an impossible position when they were asked to organize delegations like this.

So that kind of sums up the civilian or “law enforcement” approach toward national cyber security.

That leaves us to consider the much discussed alternative, specifically a shift in policy toward giving the intelligence community leadership in providing cyber national security. There have been attempts in the past to give the Intelligence Community greater responsibility for cyber security, but while the Intelligence Community seemed to have the technical resources to address these responsibilities, they were often confused by the mission and hampered by legislation and culture. By temperament, the Intelligence Community is about collection and analysis of information. Once you start asking them to do something about a situation that they have studied or understand well, you are often asking them to not just change their mission but also act against the very culture that made them successful. To understand a situation, the Intelligence Community works quietly, secretly, and in the shadows. To take action, they have to emerge for the shadows and act very publically. This transition can be difficult and even disastrous. Such transitions can give you the Bay of Pigs, non-judicial detention at Gitmo, and odd-ball assassinations–all sorts of activities that people hate because the actions themselves were not “peer-reviewed” as best security practices.

It’s not that the Intelligence Community is incompetent (well everyone makes mistakes or hides them), it’s just that that transition from intelligence/information collection to public coordination, and policy leadership, with all of the very public meetings, policy reviews, and planning drives the Intelligence Community from a position of strength and expertise to new ground. Unfortunately, another strong element of the culture of the Intelligence Community is that if the President calls, “they haul…” They just can’t bring themselves to say no, even if it’s a bad idea.

That brings us to the question, who should be responsible for cyber security? Well, every government agency wants the mission because of the funding that goes with it. But, it’s not clear who has the right perspective and culture. I suspect that the right answer is to combine the experience, and technical know-how from several agencies and to develop some new capabilities. This means that leadership of the effort has to be unambiguous. That is precisely why I believe the Obama Administration will keep the leadership on their new approach to Cyber Security right inside the White House itself. That really shouldn’t be a surprise since that is exactly what the Obama as a candidate said he would do.

Enigma Machines Collection at the National Cryptologic Museum photo by brewbooks.

• In Response to “Cyber Security Coming to a Boil” Comments….
• Inside the Obama Administration’s Cyber Security Agenda
• Beware the Cyber-Katrina!
• Blow-By-Blow on S.773–The Cybersecurity Act of 2009–Part 3
• The World Asks: is S.773 Censorship?

While you were looking the other way, OMB released their Fiscal Year 2008 Report to Congress on Implementation of The Federal Information Security Management Act of 2002.  Mostly it’s just the verbatim responses from the agencies and a rollup of the numbers with scarcely any analysis.

It’s interesting to contrast this with last year’s report which had a huge chunk of analysis.  In my cynical hours, I like to mentally replace “analysis” with “spin”, but not today.  =)

Another interesting thing is that since they published the actual responses, you can get some analysis like Angela Gunn of BetaNews provides.

My opinion: metrics are good, raw data is better.

Government transparency in action?  Maybe.  New staffers at OMB? Also likely.

Another interesting and related article is this one from Federal Computer News on Government security metrics. Yes, they need to be reconsidered, but for the most part the existing metrics are aimed at the major provisions of FISMA the LAW which is very high-level and very management-centric.  But hey, that’s what the law is supposed to provide, but more on that later.

• FISMA Report Cards Issued–Response is Rote by Now
• Next Up in Security Legislation: S3474
• GAO’s 5 Steps to “Fix” FISMA
• OMB Wants a Direct Report
• FISMA Report Card News, Formulas, and 3 Myths

Interesting article in Security Focus on President Obama and cybersecurity.  Yes, I complained on twitter because the “document on homeland security” is not really any kind of a solution, more like a bullet list of goals that sound suspiciously like a warmed-over campaign platform.

Guess what?  Every President does this, they put out their agenda for everyone to see.  With the last administration, it was the 5-point President’s Management Agenda.

Let’s be honest here, as Bubba the Infantryman would say, “There are only a couple of ways to suck an egg, and this egg has been around for a long time.”  Any cybersecurity strategy will harken back to the National Strategy to Secure Cyberspace because the problems are the same.  If you remember back to when the NStSC was first released, a horde of critics appeared out of the woodwork to say that there wasn’t enough implementation details and that the strategy wouldn’t be implemented because of that.  Well, they were partly right.

And now there’s the President stating his agenda with the same ideas that people have been saying for 6 years in more detail than what and suddenly it’s new and innovative.  That’s politics for you, folks.  =)  Bubba, in a rare fit of wisdom would say “The way you can tell the true pioneers is that they have arrows sticking out of their backs” and it might seem apropos here, if maybe a little bit cynical.

Hidden Agenda Eats Agenda photo by emme-dk.

Let’s go through each of the points with a little bit of analysis from myself:

Great idea.   Between OMB, NIST, DHS, DoD, DOJ, and a cast of thousands, there is a huge turf war over who really owns security.  Each of these groups do a phenomenal job doing what it is they do, but coordination between them is sometimes more like a semi-anarchist commune than a grand unified effort.  I seem to remember saying at one point that this was needed.  Granted, I was specifically talking about the internal side of the InfoSec Equitites Issue, so the scope here is a little different.

The Cyber Czar is literally buried deep down inside DHS with no real authority, a presidential advisor like is in the agenda would report directly to the President. 

We have a very good R&D plan in place (.pdf caveat), it just needs to be adopted and better funded.  For those of you who need a project, this is like a wishlist on things that some very smart Government guys are willing to fund.

Ouch, I cringe when I read this one.  Not that it’s needed because when it really comes down to it, every CISO in the US is dependent on the software and hardware vendors and their service providers.

Something the world outside the Beltway doesn’t understand is that “standards” are roughly equal to “regulation”.  It’s much, much better if the Government goes to industry groups and says “hey, we want these things to be part of a standard, can you guys work to put it all together?” There might be some regulation that is needed but it should be kept as small as possible.  Where the Government can help is to sponsor some of the standards and work along with industry to help define standards.

Maybe the best model for this is the age-old “lead the horse to water, demonstrate to the horse how to drink, hold the horses mouth in the water, and you still can’t get them to drink.”  We’ve tried this model for a couple of years, what is needed now is some kind of incentive for the horse to drink and for vendors to secure their hardware, software, firmware, and service offerings.

Maybe this gets down to political beliefs, but I don’t think this is the Government’s responsibility to prevent corporate cyber-espionage, nor should you as a company allow the Government to dictate how you harden your desktops or  where you put your IDS.  If you are not smart enough to be in one of these high-tech industries, you should be smart enough to keep your trade secrets from going offshore, or else you’ll die like some weird brand of corporate darwinism.

Government can prosecute evildoers and coordinate with other countries for enforcement efforts, which is exactly what you would expect their level of involvement to be.

Yes, in some cases when it’s cyber-espionage directed at the Government by hacking contractors or suppliers (the military-industrial complex), then Government can do something about it with trickle-down standards in contracts, and they usually do.  Think ITAR export controls scoped to a multi-national corporation and you have a pretty good idea of what the future will hold.

This point is interesting to me.  We already have rules to flag large transactions or multiple transactions, that’s how Elliot Spitzer got caught.  Untraceable Internet payment schemes sounds like pulp-fiction stuff and income tax tracking to me, I would like to know if they really exist.

On the other hand, law enforcement does need training.  There really is a shortage of people with the law enforcement and technical security backgrounds who can do investigations.

National data breach law == good, because it standardizes all of the state laws that are such a hodge-podge you need a full-time staff dedicated to breaking down incidents by jursidiction.  We have something like this proposed, it’s S.459 which just needs to be resurrected and supported by the Executive Branch as part of their agenda.

A common standard could be good as long as it’s done right (industry standards v/s Government regulation), see my comments above.

Note some key points I want you to take away:

Nothing is new under the sun.  These problems have been around a long time, they won’t go away in the next 4 years.  We have to build on the work of people who have come before us because we know they’ve looked at the problem and came to the same conclusions we will eventually come to.

Partnership is emphasized.  This is because as much lip-service we give to the Government solving our problems, the American Way (TM) is for the Government not to be your Internet Nanny.  Government can set the environment to support private information security efforts but it really is up to the individual companies to protect themselves.

Industry needs to solve its own problems.  If you want the Government to solve the nation’s information security problems, it means that we take US-CERT and have them monitor everything whether you want them to or not.  Yes, that’s where things are heading, folks, and maybe I just spilled the beans on some uber-secret plan that I don’t know about yet.  Trust me, you don’t want the transparency that the Government watching your data would provide.

Be careful what you ask for.  You just might get it.  When it comes to IT security, be extra careful because you’ll end up with regulation which means more auditors.

Agenda Grafitti photo by anarchosyn.

• Beware the Cyber-Katrina!
• Cyber Security coming to a boil
• 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 4
• Blow-By-Blow on S.773–The Cybersecurity Act of 2009–Part 1

Rybolov really struck a note with me (as he usually does) with his blog entry with his decision that S.3474 was a bad thing. It reminds me of a conversation I had with a friend recently. Basically she ask me why bad thing happen even after smart people put their heads together and try to deal with the problem before facing a crisis. Intrigued with her question, I asked her what specifically she was asking about. She shared that she had been thinking about the tragedy of the Titanic sinking.

Of course she was referring to the sinking of the passenger ship RMS Titanic on the evening of 14 April 1912. She made two points, first that the experts declared that the ship was “unsinkable” – how could they be so wrong. Second, she wondered how the ship could be so poorly equipped with boats and safety equipment such that there was such great loss of life.

The Titanic’s Disaster photo by bobster1985.

Little did she know that I have had an odd fascination with the Titanic disaster since childhood and have basically read much of the common public material about the event. So, I replied that that no expert had ever declared her unsinkable, that it was basically something that was made up by the press and the dark spineless things that hang around the press. However, I added the designers and owners of the ship had made much of her advanced safety features when she was launched. A critical feature was including water-tight bulkheads in her design. This was something of an advanced and novel feature at the time. What it meant was that you could poke a pretty big hole in the ship, and as long as the whole was not spread over several of these water-tight compartments she would stay afloat. The problem was that the iceberg that she hit (the Titanic, not my friend), ignored all of this a tore a big gash along about a third of the length of the ship.

So, my friend pressed again about the lack of safety equipment, especially lifeboats. I told her that the problem here was that the Titanic indeed did meet all of the safety requirements of the time. And that a big part of the problem was that the safety requirements were drafted in 1894 at a time when there were rapid changes and in the size and design of ships of this kind. Those regulations indicated that all passenger ships over 10,000 tons required 16 life boats, and that’s how many the Titanic had. At the time the regulations were written there were hardly any ships over 10,000 tons in size. However, when Titanic was launched she was designed to be over 50,000 tons when fully loaded. The fact was that if each of these lifeboats was fully loaded they could barely hold half of the of the passengers and crew of the ship if fully loaded. What is worse, when the ship did sink, not all of the boats were usable because of speed and angle in which the ship began sinking.

So, the bottom-line was that when the Titanic was reviewed by the safety accountants, they took out their check-list and went over the ship with a fine tooth comb. When the day was done the ship fully met all the safety criteria and was certified as safe.

This is where I see the parallels between root causes of the Titanic disaster and the odd situation we find ourselves in today in terms of IT security. Security by checklist –especially out of date checklists—simply doesn’t work. Moreover, the entire mental framework that mixes up accounting practices and thoughts with security discipline and research is an utter failure. Audits only uncover the most egregious security failures. And, they uncover them at a point in time. The result is that audits can be gamed, and even ignored. On the other hand, formal reviews by experienced security professionals are rarely ignored. Sometimes not all of the resources are available to militate against some of the vulnerabilities pointed out by the professionals. And sometimes there is debate about the validity of specific observations made by security professionals. But, they are rarely ignored.

Interesting enough, because of the mixed IT security record of many government agencies, Congress is proposing – more audits! It seems to me what they should be considering is strengthening the management of IT security and moving from security audits often performed by unqualified individuals and teams toward security assessments conducted by security professionals. And since professionals are conducting these proposed assessments, they should be required to comment on the seriousness of deficiencies and possible mitigation actions. An additional assessment that the professionals should be required to report on is the adequacy of funding, staffing and higher management support. I don’t really see any point in giving a security program a failing grade if the existing program is well managed but subverted and underfunded by the department’s leadership.

• FedRAMP: It’s Here but Not Yet Here
• In Other News, I’m Saying “Nyet” on S.3474
• GAO’s 5 Steps to “Fix” FISMA
• Blow-By-Blow on S.773–The Cybersecurity Act of 2009–Part 2
• “Machines Don’t Cause Risk, People Do!”