I just got back from the SCAP 2008 conference at NIST HQ, and this is a collection of my thoughts in a somewhat random order:

Presention slides are available at the NVD website

I blogged about SCAP a year ago, and started pushing it in conversations with security managers that I came across.  Really, if you’re managing security of anything and you don’t know what SCAP is, you need to get smart on it really fast, if for no other reason than that you will be pitched it by vendors sporting new certifications.

Introduction to SCAP:  SCAP is a collection of XML schemas/standards that allow technical security information to be exchanged between tools.  It consists of the following standards:

• Common Platform Enumeration (CPE): A standard to describe a specific hardware, OS, and software configuration.  Asset information, it’s fairly humdrum, but it makes the rest of SCAP possible–think target enumeration and you’re pretty close.
• Common Vulnerabilities and Exposures (CVE): A definition of publicly-known vulnerabilities and weaknesses.  Should be familiar to most security researches and patch monkies.
• Common Configuration Enumeration (CCE): Basically, like CVE but specific to misconfigurations.
• Common Vulnerability Scoring System (CVSS): A standard for determining the characteristics and impact of security vulnerabilities.  Hmmm, sounds suspiciously like standardization of what is a high, medium, and low criticality vulnerability.
• Open Vulnerability and Assessment Language (OVAL):  Actually, 3 schemas to describe the inventory of a computer, the configuration on that computer, and a report of what vulnerabilites were found on that computer.
• Extensible Configuration Checklist Description Format (XCCDF): A data set that describes checks for vulnerabilities, benchmarks, or misconfigurations.  Sounds like the updates to your favorite vulnerability scanning tool because it is.

Hall of Standards inside NIST HQ photo by ME!!!

What’s the big deal with SCAP: SCAP allows data exchanges between tools.  So, for example, you can take a technical policy compliance tool, load up the official Government hardening policy in XCCDF for, say, Windows 2003, run a compliance scan, export the data in OVAL, and load the results into a final application that can help your CISO keep track of all the vulnerabilities.  Basically, imagine that you’re DoD and have 1.5 million desktops–how do you manage all of the technical information on those without having tools that can import and export from each other?

And then there was the Federal Desktop Core Configuration (FDCC): OMB and Karen Evans handed SCAP its first trial-by-fire.  FDCC is a configuration standard that is to be rolled out to every Government desktop.  According to responses received by OMB from the departments in the executive branch (see, Karen, I WAS paying attention =)   ), there are roughly 3.5 Million desktops inside the Government.  The only way to manage these desktops is through automation, and SCAP is providing that.

He sings, he dances, that Tony Sager is a great guy: So he’s presented at Black Hat, now SCAP 2008 (.pdf caveat).  Basically, while the NSA has a great red-team (think pen-test) capability, they had a major change of heart and realized, like the rest of the security world (*cough*Ranum*cough*), that while attacking is fun, it isn’t very productive at defending your systems–there is much more work to be done for the defenders, and we need more clueful people doing that.

Vendors are jumping on the bandwagon with both feet: The amount of uptake from the vulnerability and policy compliance vendors is amazing.  I would give numbers of how many are certified, but I literally get a new announcement in my news reader ever week or so.  For vendors, being certified means that you can sell your product to the Government, not being certified means that you get to sit on the bench watching everybody else have all the fun.  The GSA SAIR Smart-Buy Blanket Purchase Agreement sweetens the deal immensely by having your product easily purchasable in massive quantities by the Government.

Where are the rest of the standards: Yes, FDCC is great, but where are the rest of the hardening standards in cute importable XML files, ready to be snarfed into my SCAP-compliant tool?  Truth be told, this is one problem with SCAP right now because everybody has been focusing on FDCC and hasn’t had time yet to look at the other platforms.  Key word is “yet” because it’s happening real soon now, and it’s fairly trivial to convert the already-existing DISA STIGs or CIS Benchmarks into XCCDF.  In fact, Sun was blindsided by somebody who had made some SCAP schemas for their products and they had no idea that anybody was working on it–new content gets added practically daily because of the open-source nature of SCAP.

Changing Government role: This is going to be controversial.  With NVD/CVE, the government became the authoritative source for vulnerabilities.  So far that’s worked pretty well.  With the rest of SCAP, the Government changes roles to be a provider of content and configurations.  If NIST is smart, they’ll stay out of this because they prefer to be in the R&D business and not the operations side of things.  Look for DHS to pick up the role of being a definitions provider.  Government has to be careful here because they could in some instances be competing with companies that sell SCAP-like feed services.  Not a happy spot for either side of the fence.

More information security trickle-down effect: A repeated theme at SCAP 2008 is that the public sector is interested in what Big SCAP can do for them.  The vendors are using SCAP certification as a differentiator for the time being, but expect to see SCAP for security management standards like PCI-DSS, HIPAA, and SOX–to be honest here, though, most of the vendors in this space cut their teeth on these standards, it’s just a matter of legwork to be able to export in SCAP schemas.  Woot, we all win thanks to the magic that is the Government flexing its IT budget dollars!

OS and Applications vendors: these guys are feeling the squeeze of standardization.  On one hand, the smart vendors (Oracle, Microsoft, Sun, Cisco) have people already working with DISA/NSA to help produce the configuration guides, they just have to sit back and let somebody turn the guides into SCAP content.  Some of the applications vendors still haven’t figured out that their software is about to be made obsolete in the Government market because they don’t have the knowledge base to self-certify with FDCC and later OS standards.  With a 3-year lead time required for some of the desktop applications before a feature request (make my junk work with FDCC) makes it into a product release, there had better be some cluebat work going on in the application vendor community.  Adobe, I’m talking to you and Lifecycle ES–if you need help, just call me.

But how about system integrators: Well, for the time being, system integrators have almost a free ride–they just have to deal with FDCC.  There are some of them that have some cool solutions built on the capabilities of SCAP, but for the most part I haven’t seen much movement except for people who do some R&D.  Unfortunately for system integrators, the Federal Acquisition Regulation now requires that anything you sell to the Government be configured IAW the NIST checklists program.  And just how do you think the NIST checklists program will be implemented?  I’ll take SCAP for $5Bazillion, Alex.  Smart sytem integrators will at least keep an eye on SCAP before it blindsides them 6 months from now.

Technical compliance tools are destined to be a commodity: For the longest time, the vulnerability assessment vendors made their reputation by having the best vulnerability signatures.  In order to get true compatibility across products, standardized SCAP feeds means that the pure-play security tools are going to have less things to differentiate themselves from all the other tools and they fall into a commodity market centered on the accuracy of their checks with reduced false positives and negatives.  While it may seem like a joyride for the time being (hey, we just got our ticket to sell to the Gubmint by being SCAP-certified), that will soon turn into frustration as the business model changes and the margins get smaller.  Smart vendors will figure out ways to differentiate themselves and will survive, the others will not.

Which leads me to this: Why is it that SCAP only applies to security tools?  I mean, seriously, guys like BigFix and NetIQ have crossover from technical policy compliance to network management systems–CPE in particular.  What we need is a similar effort applied to network and data center tools.  And don’t point me at SNMP, I’m talking rich data.  =)  On a positive note, expect some of the security pure-play tools to be bought up and incorporated into enterprise suites if they aren’t already.

Side notes:

I love how the many deer (well over 9000 deer on the NIST campus) all have ear tags.  It brings up all sorts of scientific studies ideas.  But apparently the deer are on birth control shots or something….

Former Potomac Forum students:  Whattayaknow, I met some of our former students who are probably reading this right now because I pimped out my blog probably too aggressively.  =)  Hi Shawn, Marc, and Bob!

Old friends:  Wow, I found some of them, too.  Hi Jess, Walid, Chris, and a cast of thousands.

Deer on NIST Gaithersburg Campus photo by Chucka_NC.

• Sir Bruce Mentions FDCC, World Goes Nuts
• Security Automation Developers Conference Slides
• Some Words From a FAR
• NIST and SCAP; Busting a cap on intruders Part 1
• Ed Bellis’s Little SCAP Project

The Potomac Forum crew is back at it again with a C&A seminar on the 15th and 16th.  While 2 days isn’t long enough to earn your black belt at C&A-Foo, it is enough so that if you’re a solid program manager or technical lead, you’ll walk out being at least able to understand the core of the process.

As usual, some of the instructors should be familiar to my blog readers.  =)

• C&A Seminar in August, Instructor-to-Coolness Ratio Goes Up!
• Certification and Accreditation Seminar, March 30th and 31st
• NIST Framework for FISMA Dates Announced
• Another 2-Day C&A Seminar
• Building A Modern Security Policy For Social Media and Government

Federal Computer Week: Senate Panel Rejects Weakening S 3474

Gene Schultz: Goodbye FISMA (as We Know It)

Let’s talk through the FCW article first, shall we?   =)

“The measure would amend the original FISMA legislation, which outlined compliance activities for agencies to meet each year. However, many agencies have turned FISMA compliance into a paperwork exercise, Carper said.”

Um, no, I don’t get that.  The original FISMA is an information security management law, this law mostly formalizes the role, responsibility, and authority of the CISO.  They intentionally named it FISMA 2008 to make people think that it was ammending the original FISMA, but it doesn’t do that.

Don’t believe the hype, this will not change the original FISMA, it’s just an addition.

“Carper said CIOs primarily develop and oversee policy, but the CISO handles the daily information security activities. He suggested that a CISO council could have a sunset date of two or three years. If the council demonstrated benefits, it could be extended, Carper said.”

OK, fair enough on the cost and coordination, but what the CISO council objectionists don’t understand is that the CIOs don’t know all of the nuts and bolts of security, that’s why we have CISO as a mandatory position in this bill–so that the CIO has a subject-matter-expert to help them out.  Yes, it’s that specialized as a profession.

Now for Gene Schultz:

“First and foremost, to comply with this statute involves generating huge amounts of paperwork to document actions (or lack thereof) taken to address the many areas that FISMA describes. A completely ineffective security practice can get high FISMA marks, as has happened numerous times before.”

OK, this is a little lesson on FISMA paperwork:  people are doing 4x what they should be doing for the following reasons:

• The people doing the writing do not know what they are actually doing
• The agency’s security program is not mature enough to have shared/common controls
• In the world of auditors, if it’s not written down, it doesn’t exist
• CYA purposes–I told you this was a risk

So you think you’re going to do any better with any other framework/law and the same people executing it?

“Two US Senators, Joseph Lieberman of Connecticut and Tom Carper of Delaware, have recently introduced a Senate bill that would render the 2002 version of FISMA obsolete.”

No, to be bluntfully honest, the old version of FISMA will still be around.  Somebody’s been drinking the kool-aid from the lawmakers and the press machine.  If anything, this adds more junk that you can get audited on and an additional layer of paperwork to demonstrate that you have met the provisions of FISMA 2008.

Post No Bills photo by striatic.

Note to our nation’s Lawmakers: as long as you approach information security from the compliance angle, we as a government are doomed to failure and to turn the entire thing into the checklist activity because the people who evaluate compliance are auditors who only know checklists–it’s not a law problem, it’s a people and skills problem.

This bill is actually pretty good with the exception of divorcing the mission owners from the security of the systems that support their mission.

However, if you think that you can reduce the compliance trap by adding more things that will end up on a compliance checklist, you have to be kidding yourself or you don’t understand the auditor mentality.

I keep reconvincing myself that the only way the government can win at security is to promote programs to develop people with security skills.  Of course, that isn’t as sexy as throwing out a bill that you can claim will make FISMA obsolete.

And finally, for those of you playing along at home, the Thomas entry for S 3474, the bill’s page on Washington Watch and the bill’s page on GovTrack.

• Next Up in Security Legislation: S3474
• In Other News, I’m Saying “Nyet” on S.3474
• Senate Homeland Security Hearings and the Lieberman-Carper-Collins Bill
• A Funny Thing Happened Last Week on Capital Hill
• “Machines Don’t Cause Risk, People Do!”

And here we have it, a bill introduced by Senators Carper and Lieberman to increase security in the Government, known as FISMA 2008. I’m still waiting on the text to appear on the Thomas entry, but I’ll go through the major provisions from the congressional record.

Article from NextGov

Thomas Reference

Congressional Record of the Bill’s Introduction and text (Starts on CR 8388 and goes through CR 8391)

Major provisions:

• Changes some definitions of “assessment”, “audit” and “evaluation”. OK, I had to do some research on this one.  Thankfully, this is all online.  Sidenote: it’s not Section 3545 as per the bill, it’s Section 3535.  Basically this is just rewording and rescoping of annual audits to be written the way it should have been in the first place.
• Creates a CISO position at each agency. Hey, I thought this was already created by FISMA.  What we need is not CISOs that work for the CIO, what we need are agency CSOs (I’ll even take an agency Chief Risk Officer) that have authority over all of security, not just IT geek concerns.
• Creates a CISO Council. Fantastic idea, how come I didn’t think of it?
• Qualifications for CISOs. Not a bad idea, but the bill doesn’t elaborate too much.
• Responsibilities for CISOs. This is an interesting section.  Much of this is in guidance from NIST/DISA/CNSS already.  I like most of these measures, but I’m not sure that they need to be codified into law except for the pieces that reside outside of the agencies, like the coordination with US-CERT.  Putting the CISO’s responsibilities into law does give the CISO more teeth if they need it, but you have to wield the law carefully.

The Law photo by F.S.M.

From the NextGov article and the congressional record:

“Our bill empowers chief information security officers to deny access to the agency network if proper security policies are not being followed. If we are going to hold these hardworking individuals accountable in Congress for information security, then we should give them the authority to do so,” said Carper.

Um, yeah, we’ve given them the authority in this bill, but my problem is that it completely removes the DAA/AO/mission owners from the picture–the CISO is now responsible for the secure operations of IT systems and has disconnect authority.

I think that philosophically this bill is a step backwards.  The more progressive thought is that security is the responsibility of the agency head and the mission owners and that the CISO just provides support as a subject matter expert.  Under this bill, we’re back to a world where the CISO is the sole decision-maker when it comes to security.  Wow, that’s so… 1990’s-ish.

However, we all know that the CISOs are the people getting the security job done from day to day, and this bill makes sense if you assume that the agency heads and DAAs/AOs have 0 interest or skills to assist in the security of their data.  That might or might not be true, I’ll leave it up to you to decide.

Questions for today are these (and yes, I want to hear what you think):

• Are we willing to scrap the “business/system owner” concepts that our security management processes are modeled around?
• Are we willing to admit that the DAA/AO concept is a failure because of lack of understanding and capabilities on their part?
• Are the mission owners willing to take an outage on their supporting IT infrastructure because the CISO took the system offline because they didn’t secure the system properly in the first place?
• Can we rely on a management technique where the stakeholders are removed from the decisionmaking of a trained expert?

• Ooh, “The Word” is out on S 3474
• In Other News, I’m Saying “Nyet” on S.3474
• Some Comments on SP 800-39
• Needed: Agency CSOs
• When the News Breaks, We Fix it…

First, some links:

• Washington Technology
• Federal News Radio
• Federal Computer Week
• The RFI on FEDBIZOPS

Synopsis: DoD wants to know how its system integrators protect the “Controlled Unclassified Information” that they give them.  Hmm, sounds like the fun posts I’ve done about NISPOM, SBU and my data types as a managed service provider.

This RFI is interesting to me because basically what the Government is doing is collecting “best practices” on how contractors are protecting non-classified data and then they’ll see what is reasonable.

Faustian Contract photo by skinny bunny.

However, looking at the problem, I don’t see this as much of a safeguards issue as I do a contracts issue.  Contractors want to do the right thing, it’s just that they can’t decide if security is which of these things:

• A service that they should include as part of the work breakdown structure in proposals.  This is good, but can be a problem if you want to keep the solution cheap and drop the security services from the project because the RFP/SOW doesn’t specify what exactly the Government wants by way of security.
• A cost of doing business that they should reduce as much as possible.  For system integrators, this is key:  perform scope management to keep the Government from bleeding you dry with stupid security managers who don’t understand compensating controls.  Problem with this approach is that the Government won’t get all of what they need because the paranoia level is set by the contractor who wants to save money.

Well, the answer is that security is a little bit of both, but most of all it’s a customer care issue.  The Government wants security, and you want to give it to them in the flavor that they want, but you’re still not a dotorg–you want to get compensated for what you do provide and still make a profit of some sort.

Guess what?  It takes cooperation between the Government and its contractors.  This “Contractor must be compliant with FISMA and NIST Guidelines” paragraph just doesn’t cut it anymore, and what DoD is doing is to research how its contractors are doing their security piece.  Pretty good idea once you think about it.

Now I’m not the sharpest bear in the forest, but it would occur to me that we need this to happen in the civilian agencies, too.  Odds are they’ll just straphang on the DoD efforts. =)

• When the Feds Come Calling
• Splunk Goes After the FISMA Lucre, They’re not Alone
• When the News Breaks, We Fix it…
• Security Assessment Economics
• Surprise Report: Not Enough Security Staff

Not to turn my blog into a place for twitter-short posts, but check out this announcement  by Cisco WebEx about their security management, audits, and SAS-70 stukas.

Fruck, it’s almost like somebody’s reading my posts on cloud computing and the Government.  This is good as long as WebEx can execute.  =)

• Cloud Computing and the Government
• SP 800-53A Now Finally Final
• Coming Soon to a Cloud Near You…
• Reinventing FedRAMP
• Some Comments on SP 800-39