I’ve seen the scenario about a dozen times in the last 2 months–contractors and service providers of all sorts responding to the Government’s security requirements in the middle of a contract.  It’s almost reached the stage where I have it programmed as a “battle drill” ala the infantryman’s Battle Drill 1A, and I’m here to share the secret of negotiating these things.

Let’s see, without naming names, let’s look at where I’ve seen this come up:

• Non-Government Organizations that assist the Government with para-Government services to the citizens
• Companies doing research and development funded by the Government–health care and military
• Universities who do joint research with the Government
• Anybody who runs something that the Government has designated as “critical infrastructure”
• State and local governments who use Federal Government data for their social plans (unemployment system, food stamps, and ) and homeland security-esque activities (law enforcement, disaster response)
• Health Care Providers who service Government insurance plans

For the purposes of this blog post, I’ll refer to all of these groups as contractors or service providers.  Yes, I’m mixing analogies, making huge generalizations, and I’m not precise at all.  However, these groups should all have the same goals and the approach is the same, so bear with me while I lump them all together.

Really, guys, you need to understand both sides of the story because this a cause for negotiations.  I’ll explain why in a minute.

On the Government side:  Well, we have some people we share data with.  It’s not a lot, and it’s sanitized so the value of it is minimal except for the Washington Post Front Page Metric.  Even so, the data is PII that we’ve taken an anonymizer to so that it’s just statistical data that doesn’t directly identify anybody.  We’ve got a pretty good handle on our own IT systems over the past 2 years, so our CISO and IG want us to focus on data that goes outside of our boundaries.  Now I don’t expect/want to “own” the contractor’s IT systems because they provide us a service, not an IT system.  My core problem is that I’m trying to take an existing contract and add security requirements retroactively to it and I’m not sure exactly how to do that.

Our Goals:

• Accomplishing the goals of the program that we provided data to support
• Protection of the data outside of our boundaries
• Proving due-diligence to our 5 layers of oversight that we are doing the best we can to protect the data
• Translating what we need into something the contractor understands
• Being able to provide for the security of Government-owned data at little to no additional cost to the program

On the contractor/service provider side:  We took some data from the Government and now they’re coming out of the blue saying that we need to be FISMA-compliant.  Now I don’t want to sound whiney, but this FISMA thing is a huge undertaking and I’ve heard that for a small business such as ourselves, it can cripple us financially.  While I still want to help the Government add security to our project, I need to at least break even on the security support.  Our core problem is to keep security from impacting our project’s profitability.

Our Goals:

• Accomplishing the goals of the program that we were provided data to support
• Protection of the data given to us to keep the Government happy and continuing to fund us (the spice must flow!)
• Giving something to the Government so that they can demonstrate due-diligence to their auditors and IG
• Translating what we do into something the Government understands
• Keeping the cost of security to an absolute minimum or at least funded for what we do add because it wasn’t scoped into the SOW

Hmm, looks like these goals are very much in alignment with each other.  About the only thing we need to figure out is scope and cost, which sounds very much like a negotiation.

Hardcore Negotiation Skills photo by shinosan.

Little-known facts that might help in our scenario here:

• Section 2.4 of SP 800-53 discusses the use of compensating controls for contractor and service-provider systems.
• One of the concepts in security and the Government is that agencies are to provide “adequate security” for their information and information systems.  Have a look at FISMA and OMB Circular A-130.
• Repeat after me:  “The endstate is to provide a level of protection for the data equivalent or superior to what the Government would provide for that data.”
• Appendix G in SP 800-53 has a traceability matrix through different standards that can serve as a “Rosetta Stone” for understanding each other.  Note to NIST:  let’s throw in PCI-DSS, Sarbanes-Oxley,  and change ISO 17799 to 27001.

So what’s a security geek to do?  Well, this, dear readers, is Rybolov’s 5-fold path to Government/contractor nirvana:

1. Contractor and Government have a kickoff session to meet each other and build raport, starting from a common ground such as how you both have similar goals.  The problem really is one of managing each others’ expectations.
2. Both Government and Contractor perform internal risk assessment to determine what kind of outcome they want to negotiate.
3. Contractor and Government meet a week later to negotiate on security.
4. Contractor provides documentation on what security controls they have in place.  This might be as minimal as a contract with the guard force company at their major sites, or it might be just employee background checks and
5. Contractor and Government negotiate for a 6-month plan-of-action.  For most organizations considering ISO 27001, this is a good time to make a promise to get it done.  For smaller organizations or data , we may not even

Assumptions and dependencies:

• The data we’re talking about is low-criticality or even moderate-criticality.
• This isn’t an outsourced IT system that could be considered government-owned, contractor-operated (GO-CO)

• Imagine that, System Integrators Doing Security Jointly with DoD
• How to Not Let FISMA Become a Paperwork Exercise
• Random Thoughts on “The FISMA Challenge” in eHealthcare
• “Machines Don’t Cause Risk, People Do!”
• Introducing the Government’s Great InfoSec Equities Issue

In part 1 on this blog I outlined the fact penetration testing evolved from a grey-art practiced by hackers into a more formal process.  This evolution has created a bifurcation within “boutique” penetration test service providers.

On the one hand tools-oriented budget firms offer little value added beyond simply running simple vulnerability scans.  On the other more profession and experienced firms offer the same tests and scans but also offer analysis that can be offered as direct actionable input into an organization’s existing security governance structure. 

The fly in the ointment is that not all security consumers or security organizations are created equally.  Some IT security organizations can be characterized a compliance-based.  That is to say that they establish and follow a set of rule that they believe will put them on the road to IT security.

On the other hand, most IT security organizations are risk-based and technically oriented.  They also follow a formal structure but, addressing risk with the appropriate application of process, procedures, and technology.  In  graphical terms the situation would appear to line-up as depicted in table 1.  Table quadrant 1 representing a weak security organization supported by, “Tool-boys” is noted in red because the risks associated with this coupling.  Quadrants 2 and 3 are noted in yellow because of the risks associated with either a weak security organization or weak testing input.  

Table 1

However, in the real world the table should look more like Table 2. With the increasing acceptance of Compliance-based security models, a set of independently administered vulnerability scans suffices to “check the box” for the requirements for a penetration test.  This is good news for these budget “boutique” firms. 

Table 2

However, as might be expected, it is bad news for IT security in general since all networks live in the same security ecosystem.   Market drivers that encourage poor security practices hurt us all.

Hacker Store photo by LatinSuD.

• Evolution of Penetration Testing: Part 1
• NIST and SCAP; SCAP @ Large Part 2
• Comments on SCAP 2008
• An Open Letter to NIST About SP 800-30
• Core Belief #4 — Compliance is a Dead-End

Let’s talk about TIC today, dear readers, for I smell a conspiracy theory brewing.

For those of you who missed the quick brief, TIC is short for “Trusted Internet Connections” and is an architecture model/mandate/$foo to take all of the Internet connections in the Government (srsly, nobody knows how many of them really exist, but it’s somewhere in the 2,000-10,000 range) and consolidate them into 50.  These connections will then be monitored by DHS’s Einstein program.

No, Not That Kind of TIC photo by m.prinke.

Bringing you all up to date, you’ll need to do some homework:

• OMB Memo 08-05, “Implementation of Trusted Internet Connections (TIC)”
• Planning Guidance for Trusted Internet Connections (TIC)
• Final Trusted Internet Connections (TIC) Initiative Statement of Capability Evaluation Report, dated June 4, 2008
• OMB Memo 08-27 Guidance for Trusted Internet Connection (TIC) Compliance

Now having read all of this, some things become fairly obvious:

• If you have the following people needing connections:
  • 24 agencies, plus
  • DoD with 2 points of presence, plus
  • Intelligence agencies with a handful of Internet connections, means that:
• That basically, everybody gets one Internet connection.  This is not good, it’s all single point-of-DOS.
• Agencies have been designated as Internet providers for other agencies.  Sounds like LoB in action.
• Given the amount of traffic going through the TIC access points, it most likely is going to take a significant amount of hardware to monitor all these connections–maybe you saved 50% of the monitoring hardware by reducing the footprint, but it’s still hardware-intensive.
• TIC is closely tied with the Networx contract.
• In order to share Internet connections, there needs to be a network core between all of the agencies so that an agency without a TIC access point can route through multiple TIC service provider agencies.

And this is where my conspiracy theory comes in:  TIC is more about making a grand unified Government network than it is monitoring events–Einstein is just an intermediate goal.   If you think about it, this is where the Government is headed.

We were headed this way back in ought-two with a wonderful name: GovNet.  To be honest, the groundwork wasn’t there and the idea was way ahead of its time and died a horrible death, but it’s gradually starting to happen, thanks to TIC, FDCC, and Einstein. 

More fun links:

• Wired GovNet Article
• FCW GovNet Article
• Gartner Email Analysis on GOVNET (Note this gem: “Enterprises and government agencies should assume that a long-term solution to Internet security will arise elsewhere and should proceed to buy denial-of-service protection and other managed security services from commercial providers.”)

If you want to get a reaction out of the OMB folks, mention GovNet and watch them backpedal and cringe,–I think the pain factor was very high for them on GovNet. So I think that we should, as a cadre of information security folks, start calling TIC what it really is:  Govnet 2.0!  =)

• Comments on SCAP 2008
• The 10 CAG-egorically Wrong Ways to Introduce Standards
• In Response to “Cyber Security Coming to a Boil” Comments….
• Federated Vulnerability Management
• How I Became the Owner of Two Rogue WiFi APs

There is another challenge that SCAP addresses without it being officially on the SCAP program’s agenda.  With the advent of SCAP we now have a common reporting criteria by which we can now judge SCAP certified products.  If you have ever used an automated vulnerability scanner as part of a penetration test or security audit, you know that not all vulnerability scanners are created equal.  Some have much lower false positive alert and reporting rates than others.  Likewise, it is known that false negative alert and reporting rates vary.  And, because of the various technical approaches taken by the scanners, some provide much more consistent results. The challenge has been that without a common criteria to test against, it is difficult for a small or even fairly large security organization to find the resources to effectively test these products in a fair apples to apples test.

This is where NIST has a real opportunity on its hands.  With the release of the SCAP protocol, we have the criteria by which performance comparisons can be made.  What we are lacking is a common test environment.

Benchmark photo by bzo.

Let me veer off-topic for a moment to provide some background.  In the last few years the Linux community has created various “live distributions” for various specialized requirements.  What live distributions are, are CD, DVD or Flash-media-based operating systems that are executed upon boot.  That is to say that they boot and run directly from CD or DVD.  So, by using a Linux live distribution, you can run Linux off of you home Windows-based laptop without ever installing Linux to your hard disk.  This has opened up a world of specialized possibilities for this community.  One of them is the standardized training environment.  For example, security testers have created DVL (damn vulnerable Linux http://www.damnvulnerablelinux.org/).  DVL is a live distribution that with well documented security vulnerabilities, this distribution is used as a training aid for teaching vulnerability assessment and mitigation. There are other similar efforts created with the same intent such as the excellent DE-ICE training targets (http://de-ice.net/hackerpedia/index.php/De-ICE.net_PenTest_Disks).

NIST could follow-up on the release of the SCAP protocol by also building and releasing a common testing environment based perhaps on live distribution technology. Such an environment with well documented vulnerabilities would allow for the creation of objective benchmarks to be created to rate the accuracy, reproducibility, completeness of the results of SCAP certified vulnerability testing and reporting products.  This would aid government agencies, businesses and even individuals in their purchasing decisions.  It would also allow provide vendors with an objective and common test environment in which they can test and improve their products.  I admit this would be a significant undertaking for NIST.  However, I would suggest that such a test environment could be designed in such a manner that it could be built and released as a series of inter-operable modules based on live distribution technology.  The initial release might only offer a relatively modest set of tests but with the release of each module building on the results of previous releases, a highly demanding and sophisticated test environment could soon be realized.  Because of the importance and utility of such a project, industry and outside security experts might want to participate in and contribute to such an endeavor.

• NIST and SCAP; Busting a cap on intruders Part 1
• Ed Bellis’s Little SCAP Project
• Comments on SCAP 2008
• Federated Vulnerability Management
• How to Not Let FISMA Become a Paperwork Exercise

No big surprise by now, I work for an accounting firm.  Oh, what’s that?  Oh yes, that’s right, it’s a consulting firm with a high percentage of accountants, including a plethora of CPAs.  “Accounting firm” is so 1950s-ish. =)

It’s my secret theory (well, not so much of a secret now, just between the Internet and me) that the primary problem we have in information security is that as a field we have borrowed heavily from public accounting.  The only problem is that public accounting is different from what we do.

Goals for public accounting run something like this:

• Eliminate fraud through oversight
• Protect the company’s money from rogue agents
• Protect the shareholders of public companies
• Ensure accountability of actions

Accounting for Non-Accountants photo by happyeclair.

As a result of their goals, accountants have an interesting set of values:

• Signatures are sacred
• Separation of duties is sacrosanct
• Auditing is designed to act as a deterrent to fraud
• “Professional Skepticism” is a much-valued trait
• Zero-Defects is a good condition

In other words, accountants live in a panopticon of tranparency, the concept being that through oversight and transparency, people will not become evildoers and those that do will be caught.  Pretty simple idea, makes me think about IDS in an entirely new light.

Words that accountants use that mean something entirely different from the way you or I use them:

• Fraud, Waste, and Abuse: They’re talking about spending money, I’m usually talking about people doing something ethically wrong.
• Investigation: They’re looking at the numbers to see how a particular number was created.  Me, I bring the nice people with guns when I do an investigation.
• Incident: Their version is what I would call an event.  When I call something an incident, we’re headed towards an investigation.
• Security test and evaluation: To them, it’s a compliance audit.  To me, it’s determining the frequency that the system will fail and if we have a way to fix it once it does.  Remember this, it’s a critical difference.
• Control: I think their version has something to do with having oversight and separation of duties.  Me, when I see this word, I think “countermeasure to a specific threat and vulnerability”.
• Audit: An activity designed to prove that fraud has not happened.  Usually we don’t use the word unless we absolutely have to.
• Technical: They’re talking about the highly-detailed accounting rules.  I’m talking about if you know how to build your own server and OS using lumps of raw silicon and a soldering iron.
• Checklist: They’re talking about a sacred list that condenses all the rules into an easily-auditable format.  Me, I’m thinking that a checklist is something that will fail because my threats and their capabilities don’t fit into nice little lists.
• Forensics: Their version is what I would call “research to find out where the money went to” and involves looking at a bunch of numbers.  My version has something to do with logs, memory dumps, and hard drive images.
• Risk Management: This has something to do with higher interest rates for high-risk loans.  For me, it’s looking for countermeasures and knowing what things to skimp on even though the catalog of controls says you have to have it.

In short, pretty much anything they could say about our line of work has a different meaning.  This is why I believe it’s a problem if we adopt too much of their methodology and management models because they are doing similar activities to what security people do, only for different purposes.

In order to understand the mentality that we’re working with, let’s give you a couple of scenarios:

After-Work Optional Training Session: The accountants not only make you put your name on the attendance roster but you have to sign it as well.  Are they worried that you’re committing fraud by showing up at training that you were not supposed to, so they need some sort of signature nonrepudiation to prove that you were there?  No!  They just make you sign it because they believe in the power of the signature and that’s just how they do things, no matter how trivial.

The Role of Security: To an accountant, the role of security in an organization is to reduce fraud by “hack-proof” configurations and monitoring.  This is a problem in that since security is economics, we’re somehow subordinate to the finance people.

Let’s look at the world of the typical security practitioner:

• The guidance that security professionals have is very contradictory, missing, or non-relevant.
• Really what we do comes down to risk management, which means that sometimes it makes more sense to break the rules (even though there is a rule that says break the rules, which should freak your brain out by now if you’re an accountant).
• We have a constantly changing environment that rules cannot keep up with.

Now this whole blog post, although rambling on about accountants, is aimed at getting a message across.  In the US Federal Government, we use a process called certification and accreditation (C&A).  The certification part is pretty easy to understand–it’s like compliance, do you have it and does it work.  CPAs will readily understand that as a controls assessment.  That’s very much a transferable concept.

But in accreditation, you give the risks to a senior manager/executive and they accept the risks associated with operating the system.  The CPA’s zero-defects world comes through and they lie on the ground doing the cockroach.  Their skills aren’t transferable when dealing with risk management, only compliance with a set of rules.

Once again, the problem with security in Government is that it’s cultural.

And don’t get me wrong, I like accountants and they do what I do not have neither the skills nor the desire to do.  I just think that there aren’t as many transferable skills between our jobs as there might seem on the surface.

• White Professional Male Turned CISSP Seeks Mega-Sized Security Management Model
• An Open Letter to NIST About SP 800-30
• How to Not Let FISMA Become a Paperwork Exercise
• Security Assessment Economics
• Split-Horizon Assessments and the Oversight Effect

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