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

This article at SC Magazine is exactly why.  Kudos to Dan Philpott for calling the author on his errors.

Things that go through my mind about articles like this:

• Is it that slow of a news day?  FISMA stuff is always good for a couple yucks when there’s nothing else to talk about.  Looks like somebody needed filler while everybody was flying to Black Hat and DefCon.
• Once again, we’re confusing FISMA the law with the implementation thereof.  Yawn.
• Ack, somebody who likes FDCC.  Actually, I like it too in theory, I just don’t like the implementation.
• “Government has influence when it comes to awareness and will have opportunities to use it.”  Um, yes, it’s the $75B IT budget, flex that muscle wherever you want to get the secure products you want.  Do not underestimate the power of the budget.
• Follow the FISMA Naysayer and spot somebody who’s looking for money.  In this case, it’s Fortify.

Funny thing is that I think I met the guy from Fortify a couple of months ago at a NoVa OWASP meeting for a showing of their fun-but-FUDtastic movie about application security.  You know, you’ve seen the trailer, it looked like this:

There is a way to influence thinking in this town, and writing trash articles like this is not the way to do it.  If Fortify really wants to change the world, I have some ideas on how to do it, but nobody ever asks.  =)

FUD Truck Makes a Delivery photo by crmudgen23.

Guerilla CISO story time:

About 9 months ago, I got a marketing packet from Borderware.  It said that “FooCorp is identified as sending spam” and offered me the opportunity to join their reputation service.

Looking at the materials they sent me, I deduced that none of the source IPs they listed was in our netblock and that what they were referring to was spam using @foocorp.com email addresses as the “from” address.  Um, not a whole lot you can do to stop that, although it does make for some fun abuse@ emails from users who don’t understand how spam works:  “Quit sending me this stuff, I’ll burn down your data center myself!!!111oneoneone”

Anyway, since the whole packet was pure FUD and not really relevant to anything I wanted to do, I sat down and sent an email to their Director of Marketing and CTO:

I know Borderware’s products, we use them in some of our solutions, and you have a good reputation.  Please don’t resort to such a lowbrow marketing scheme because it sullies your brand.

I think Fortify is in the same boat.  They have a good reputation–I have a friend who works for one of their biggest customers, and if he’s cool with it, I am.

But the question for all security companies remains:  how do I sell my product without resorting to spreading FUD everywhere I go?

• More Vendor Craziness
• No, FISMA Doesn’t Require That, Silly Product Pushers
• Comments on SCAP 2008
• Let’s Face it, Half the Security Industry is a Pyramid Scheme
• Splunk Goes After the FISMA Lucre, They’re not Alone

Post #9678291 on why people don’t understand what FISMA really is:  Secure64 DNSSEC Press Releases.

“FISMA Act encourages U.S. government agencies to configure their DNS servers to the DNSSEC security specifications set by the National Institute of Standards and Technology, and it has been reported that the federal government’s Office of Management and Budget (OMB) plans to begin enforcing DNSSEC requirements through an auditing process, setting the standard for DNS best practices.”

Yep, if you stamp FISMA on it, people will buy it, maybe in your PR department’s wettest and wildest dreams.  Guys, it’s been 6 years, that kind of marketing doesn’t work nowadays, mostly because we spent ourselves into oblivion buying junkware similar to yours and now we’re all jaded.

Now don’t get me wrong, DNSSEC is a good thing, especially this month.  But there is something I need to address:  FISMA requires good security management with a dozen or so key indicators, not a solution down to the technical level.  Allusions to OMB are just FUD, FUD, and more FUD because unless it’s in a memo to agency heads, it’s all posturing–something everybody in this town knows how to do very well.  OMB would rather stay out of mandating DNSSEC and maybe give a “due date” once NIST has a final standard.

My one word of wisdom for today:  anybody who tries to sell a product and uses FISMA as the “compelling event” has no clue what they’re talking about.

• Some Words From a FAR
• When the News Breaks, We Fix it…
• Comments on SCAP 2008
• GAO’s 5 Steps to “Fix” FISMA
• How to Not Let FISMA Become a Paperwork Exercise

Hot on the heels of Security Assessments as Fraud, Waste, and Abuse comes this heartwarming lolcat.

• The Authorizing Official and the Lolcat
• Look Out, Sir Bruce, IKANHAZFIZMA is Coming for You
• Snowmageddon Meets the IKANHAZFIZMA Lolcats
• Happy New Year
• IKANHAZFIZMA Finds Caution Tape

I’m going to put on my Government Security Heretic Hat for awhile here, bear me out.  By my estimate, half of the security assessments received by the Government have some kind of fraud, waste, and abuse.

What makes me say this is the amount of redundancy in some testing that I’ve seen without any value added.

The way to avoid this redundancy is the concept of common/shared controls.  The whole idea is that you take whatever security controls you have across the board and put them into one bucket.  You test that bucket once and then whenever something  shares controls with that bucket, you look at the shared control bucket and make sure that the assessment is still relevant and accurate.

So, what makes a security assessment not fraud, waste, and abuse?  It’s a good assessment if it does the following:

• Does not repeat a previous assessment.
• Discovers previously-undiscovered vulnerabilities, weaknesses, or findings.
• Has findings that get fed into a risk management plan (accepted, avoided, transferred, etc–think POA&M).
• Is not exhaustive when it doesn’t need to be.
• Provides value to the project team, system owner, and Authorizing Official to make key decisions.

Now the problem is that the typical auditor has a hard time stopping–they have an ethical obligation to investigate anything that their “professional skepticism” tells them is out of place, just like cops have an ethical obligation to investigate anything that they think is a crime.

The Solution?  Don’t use auditors! The public accounting model that we adopted for information security does not scale the way that we need it to for ST&E, and we need to understand this in order to fix security in the Government.

What we need to be doing is Security Test and Evaluation which is focused on risk, not on compliance using a checklist of control objectives.  Usually if you know enough to say “Wow, your patch management process is whacked, you’re at a high risk!” then that’s enough to stop testing patch management controls.  This is one of the beefs I have with 800-53A in the hands of less-than-clueful people:  they will test until exhaustion.

There isn’t a whole lot of difference between ST&E and an audit, just the purpose.  Audits are by nature confrontational because you’re trying to prove that fraud, waste, and abuse hasn’t occured.  ST&E is helping the project team find things that they haven’t thought of before and eventually get the large problems funded and fixed.

The Little Frauds Harrigan & Hart’s Songs & Sketches Photo by Boston Public Library

• How to Not Let FISMA Become a Paperwork Exercise
• Cloud Computing and the Government
• Some Thoughts on POA&M Abuse
• 20 Critical Security Controls: Control-by-Control
• An Open Letter to NIST About SP 800-30

Check out this slideshow and this workshop paper from 2006 on some ideas that NIST and a fairly large advisory panel have put together about certification of C&A service providers.  I’ve heard about this for several years now, and it’s been fairly much on a hiatus since 2006, but it’s starting to get some eartime lately.

The interesting thing to me is the big question of certifying companies v/s individuals.  I think the endgame will involve doing both because you certify companies for methodology and you certify people for skills.

This is the problem with certification and accreditation services as I see it today:

• Security staffing shortage means lower priority:  If you are an agency CISO and have 2 skilled people, where are you going to put them?  Odds are, architecture, engineering, or some other high-payoff activity, meaning that C&A services are candidates for entry-level security staff.
• Centralized v/s project-specific funding:  Some agencies have a “stable” of C&A staff, if it’s done wrong, you end up with standardization and complete compliance but not real risk management.  The opposite of this is where all the C&A activities are done on a per-project basis and huge repetition of effort ensues.  Basic management technique is to blend the 2 approaches.
• Crossover of personnel from “risk-avoidance” cultures:  Taking people from compliance-centric roles such as legal and accounting and putting them into a risk-based culture is a sure recipe for failure, overspending, and frustration.
• Accreditation is somewhat broken:  Not a new concept–teaching business owners about IT security risk is always hard to do, even more so when they have to sign off on the risk.
• C&A services are a commodity market:  I covered this last week.  This is pivotal, remember it for later.
• Misinformation abounds:  Because the NIST Risk Management Framework evolves so rapidly, what’s valid today is not the same that will be valid in 2 years.

So what we’re looking at with this blog post is how would a program to certify the C&A service providers look like.  NIST has 3 viable options:

• Use Existing Certs: Require basic certification levels for role descriptions.  DoD 8570.1M follows this approach.  Individual-level certification would be CAP, CISSP, CG.*, CISA, etc.  The company-level certification would be something like ITIL or CMMI.
• Second-Party Credentialing:  The industry creates a new certification program to satisfy NIST’s need without any input from NIST.  Part of this has already happened with some of the certifications like CAP.
• NIST-Sponsored Certification:  NIST becomes the “owner” of the certification and commissions organizations to test each other.

Now just like DoD 8570.1M, I’m torn on this issue.  On one hand, it means that you’ll get a higher caliber of person performing services because they have to meet some kind of minimum standard.  On the other hand, introducing scarcity means that there will be even less people available to do the job.  But the big problem that I have is that if you introduce higher requirements on commodity services, you’re squeezing the market severely:  costs as a customer go up for basic services, vendors get even less of a margin on services, more charlatans show up because you’ve tipped over into higher-priced boutique services, and mayhem ensues.

Guys, I’m not really a rocket scientist on this, but really after all this effort, it seems to me that the #1 problem that the Government has is a lack of skilled people.  Yes, certifying people is a good thing because it helps weed out the dirtballs with a very rough sieve, but I get the feeling that maybe what we should be doing instead is trying to create more people with the skills we need.  Alas, that’s a future blog post….

However, the last thing that I want to see happen is a meta-game of what’s going on with certifications right now–who certifies those who certify?  I think it’s a vicious cycle of cross-certification that will end up with the entire Government security industry becoming one huge self-licking ice cream cone.  =)

• Now ISC2 Blogs have an Opinion on FISMA
• When the Feds Come Calling
• Splunk Goes After the FISMA Lucre, They’re not Alone
• Comments on SCAP 2008
• “Machines Don’t Cause Risk, People Do!”