Some of my friends (and maybe myself) will be teaching the NIST Framework for FISMA in May and June with Potomac Forum.   This really is an awesome program.  Some highlights:

• Attendance is limited to Government employees only so that you can talk openly with your peers.
• Be part of a cohort that trains together over the course of a month.
• The course is 5 Fridays so that you can learn something then take it back to work the next week.
• We have a Government speaker ever week, from the NIST FISMA guys to agency CISOs and CIOs.
• No pitching, no marketing, no product placement (OK, maybe we’ll go through DoJ’s CSAM but only as an example of what kinds of tools are out there) , no BS.

See you all there!

• Security Automation Developers Conference Slides
• C&A Seminar, October 15th and 16th
• Comments on SCAP 2008
• New SP 800-60 is Out, Categorize Yerselves Mo Better
• The “Off The Record” Track

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!”

It’s probably a shocker to most people, but I’m going to recommend that S.3474 be amended or die on the Senate floor like Caesar.

I’ve spent many hours reading over S.3474.  I’ve read the press releases and articles about it.  I’ve had some very difficult conversations with my very smart friends.

I’ve come to the conclusion that S.3474 as written/proposed by Senators Carper and Leiberman is not the answer to information security in the Government as it has been publicized repeatedly, and that anyone who believes the hype is in for a rude surprise next fall if the bill is ratified and signed.

My thoughts on the matter:

• S.3474 is not what it is being publicized as.  The people who write the press releases and the articles would have us believe that S.3474 is a rewrite of FISMA 2002 and that it focuses on continuous monitoring of the security of IT systems, both of which are a good thing.  First and foremost, it does not repeal FISMA 2002, and anyone saying that is simply trying to deceive you.  S.3474 adds to the FISMA 2002 requirements and codifies the role and responsibility of the agency CISO.
• S.3474 does not solve the core problem.  The core problem with security and the Government is that there is a lack of a skilled workforce.  This is a strategic issue that a bill aimed at execution of security programs cannot solve by itself.
• S.3474 adds to the existing checklists.  People have been talking about how S.3474 will end the days of checklists and auditors.  No, it doesn’t work that way, nor is the bill written to reduce the audits and checklists.  When you introduce new legislation that adds to existing legislation, it means that you have added more items to the existing checklists.  In particular, the provisions pertaining to the CISO’s responsibilities are audit nightmares–for instance, “How do you maintain a network disconnect capability as required by FISMA 2008” opens up a whole Pandora’s Box worth of “audit requirements” which are exactly what’s wrong with the way FISMA 2002 has been implemented.
• S.3474 puts too much of the responsibilities on the CISO.  It’s backwards thought, people.  The true responsibility for security inside of an agency falls upon that political appointee who is the agency head.  Those are the people who make the decisions to do “unsafe acts”.
• S.3474 does not solve any problems that need a solution.  Plain and simple, it just enumerates the perceived failings of FISMA 2002.  It’s more like a post-divorce transition lover who is everything that your ex-spouse is not.  Let’s see… technical controls?  Already got them.  Requirements for network monitoring?  Already got them.  2nd party audits?  Already got them.  Requirements for contractors?  Already got them.  Food for thought is that these exist in the form of guidance, does the security community as a whole feel that we need to take these and turn them into law that takes years to get changed to keep up with the pace of technology?  There is some kind of segue there into Ranum talking about how one day we will all work for the lawyers.

Of course, this is all my opinion and you can feel free to disagree.  In fact, please do, I want to hear your opinion.  But first and foremost, go read the bill.

i haz a veto pen photo by silas216

• Ooh, “The Word” is out on S 3474
• Next Up in Security Legislation: S3474
• Could the Titanic have changed course?
• Blow-By-Blow on S.773–The Cybersecurity Act of 2009–Part 2
• Senate Homeland Security Hearings and the Lieberman-Carper-Collins Bill

Something fun and new for you guys:  the estimated cost of S.3474 (.pdf caveat applies) if it were to be signed into law in its current state.  Thank you Congressional Budget Office.

Bottom line: $40M in 2009 and $570M from 2009-2013.

A quick update on S.3473:  it’s not going to get voted on by this Congress–the bill ran out of time and all of the politicians ran into campaign season so it’s hard to pin them down and get anything done.  In fact, none of the handful of security bills are going to get looked at until the next Congress.  So yeah, their fate depends on both the presidential and congressional elections next week, then let’s see if there is enough congressional bandwidth to push these bills through after the new administration transitions in.

Some of my S.3474 coverage if you’re interested.

• Next Up in Security Legislation: S3474
• Ooh, “The Word” is out on S 3474
• In Other News, I’m Saying “Nyet” on S.3474
• Could the Titanic have changed course?
• When the News Breaks, We Fix it…

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!”