Considering that it’s a secondary source and therefore subject to being corrected later in an official announcement, but this is pretty big.  Requiring the Departments and Agencies to consider cloud solutions both scares me (security, governance, and a multitude of other things about rushing into mandated solutions) and excites me (now cloud solutions are formally accepted as viable).

However, before you run around either proclaiming that “this is the death of serverhuggers” or “the end is nigh, all is lost” or even “I for one welcome our fluffy white overlords”, please consider the following:

• A “secure, reliable, cost-effective cloud option” is a very loaded statement very open to interpretation
• They already have to consider open source solutions
• They already have to consider in-sourcing
• They already have to consider outsourcing
• “Cloud” more often than not includes private clouds or community clouds
• Isn’t this just another way to say “quit reinventing the wheel”?
• Some Government cloud initiatives are actually IT modernization initiatives riding the bandwagon-du-jour
• Switching from Boeing, Northrup, and SAIC beltway bandit overlords to Google, Amazon, and SalesForce cloud overlords still mean that you have overlords

• Clouds, FISMA, and the Lawyers
• NIST Cloud Conference Recap
• FedRAMP: It’s Here but Not Yet Here
• Analyzing Fortify’s Plan to “Fix” the Government’s Security Problem
• Wanted: Some SCAP Wranglers

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

Catching you up here with some of the Gov 2.0 kids.  Steve Radick wrote an interesting blog post about Government 2.0.  And I’m thinking “damn, right on!”  Now don’t get me wrong here, sometimes I’m critical of the Gov 2.0 crowd because it seems like about half the time they’re throwing technology and data at people seeing what will stick instead of asking the non-IT program managers what information they need to have to do their job right.  But in this case, Steve’s blog post does have relevancy for Government IT security folks.

At this point, you’re probably thinking “But Mr Rybolov, how the heck does this relate to IT security and the Government?” and you’re definitely right to ask.  Well, way back in the halcyon days of last year, I came to a realization that tactical and technical security solutions come from the bottom and that compliance and regulation come from the top.  I even built a model about it.  One of the implied problem areas is that if your management model goes “top-down”, then it gets filtered through bureaucracy.

I was at an AFCEA awards banquet trying to pretend that I wasn’t really a reformed infantryman (think “professional troll”) when Roger Baker gave an awesome talk about “practicing random acts of defiance of the bureaucracy”.  I think there’s a bit of genius in that statement.  It’s one of the reasons why I blog: as a regular Joe not in the Government, I’m reasonably free to talk about the successes and failures of my friends in the Government where they can’t.

Hence my grand unified theory on life, the universe, and everything else: the InfoSec career field is a lot more like soccer or law enforcement than football and the court system–sometimes we depend on the most junior people who are operating semi-autonomously within their assigned sector.  But my point (I know, you’re wondering when I’ll get there) to this whole post is that if we’re going to have a decentralized industry, we also bear the responsibility to train our folks to operate independently and to have the skillset to be well-rounded enough to work in a wide variety of situations.

• An Open Letter to NIST About SP 800-30
• Evolution of Penetration Testing: Part 1
• Database Activity Monitoring for the Government
• Transparency in Government: Just Give us the Data!
• Random Thoughts on “The FISMA Challenge” in eHealthcare

I’ve been waiting all of September for FedRAMP to be released and hoping they get over the last-minute hurdles to put something out into view. Our lolcats will feel much more secure now with a squishy buddy.

• Lolcats Coming to you from the Cloud
• Lolcats and QR Codes
• Shmoocon: Less Moose, More LOLCATS
• Redundant Lolcats
• Lolcats, Capital Hill, and a Haiku

Ah yes, I’ve explained this about a hundred times this week (at that thing that I can’t blog about, but @McKeay @MikD and @Sawaba were there so fill in the gaps), thought I should get this down somewhere.

the 3 factors that determine how much money you will make (or lose) in a consulting practice:

• Bill Rate: how much do you charge your customers.  This is pretty familiar to most folks.
• Utilization: what percentage of your employees’ time is spent being billable.  The trick here is if you can get them to work 50 hours/week because then they’re at 125% utilization and suspiciously close to “uncompensated overtime”, a concept I’ll maybe explain in the future.
• Leverage: the ratio of bosses to worker bees.  More experienced people are more expensive to have as employees.  Usually a company loses money on these folks because the bill rate is less than what they are paid.  Conversely, the biggest margin is on work done by junior folks.  A highly leveraged ratio is 1:25, a lowly leveraged ratio is 1:5 or even less.

Site Assessment photo by punkin3.14.

And then we have the security assessments business and security consulting in general.  Let’s face it, security assessments are a commodity market.  What this means is that since most competitors in the assessment space charge the same amount (or at least relatively close to each other), this means some things about the profitability of an assessment engagement:

• Assuming a Firm Fixed Price for the engagement, the Effective Bill Rate is inversely proportionate to the amount of hours you spend on the project.  IE, $30K/60 hours=$500/hour and 30K/240 hours = $125/hour.  I know this is a shocker, but the less amount of time you spend on an assessment, the bigger your margin but you would also expect the quality to suffer.
• Highly leveraged engagements let you keep margin but over time the quality suffers.  1:25 is incredibly lousy for quality but awesome for profit.  If you start looking at security assessment teams, they’re usually 1:4 or 1:5 which means that the assessment vendor is getting squeezed on margin.
• Keeping your people engaged as much as possible gives you that extra bit of margin.  Of course, if they’re spending 100% of their time on the road, they’ll get burned out really quickly.  This is not good for both staff longevity (and subsequent recruiting costs) and for work quality.

Now for the questions that this raises for me:

• Is there a 2-tier market where there are ninjas (expensive, high quality) and farmers (commodity prices, OK quality)?
• How do we keep audit/assessment quality up despite economic pressure?  IE, how do we create the conditions where the ninja business model is viable?
• Are we putting too much trust in our auditors/assessors for what we can reasonably expect them to perform successfully?
• How can any information security framework focused solely on audit/assessment survive past 5 years? (5-10 years is the SWAG time on how long it takes a technology to go from “nobody’s done this before” to “we have a tool to automate most of it”)
• What’s the alternative?

• Security Assessment Economics
• Split-Horizon Assessments and the Oversight Effect
• Security Assessments as Fraud, Waste, and Abuse
• The CyberArmy You Have…
• How to Not Let FISMA Become a Paperwork Exercise

My talking schedule over the next couple of months:

October 25-27: SecTor in Toronto, talking on DDoS and a turbo talk on some of my barcode stuff.

November 8-11: AppSecDC in um… DC, talking on the internal security program for a cloud vendor.

And coming to you, if you give me a call.  =)

• Where is Rybolov?
• DojoCon DDoS Video
• Metricon 5 Wrapup
• The “Off The Record” Track
• Massively Scaled Security Solutions for Massively Scaled IT