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

FAR: it’s the Federal Acquisition Regulation, and it covers all the buying that the government does.  For contractors, the FAR is a big deal–violate it and you end up blackballed from Government contracts or having to pay back money to your customer, either of which is a very bad thing.

In early August, OMB issued Memo 08-22 (standard .pdf caveat blah blah blah) which gave some of the administratrivia about how they want to manage FDCC–how to report it in your FISMA report, what is and isn’t a desktop, and a rough outline on how to validate your level of compliance.

Now I have mixed feelings about FDCC, you all should know that by now, but I think the Government actually did a decent thing here–they added FDCC (and any other NIST secure configuration checklists) to the FAR.

Check this section of 800-22 out:

On February 28, 2008, revised Part 39 of the Federal Acquisition Regulation (FAR) was published which reads:
PART 39-ACQUISITION OF INFORMATION TECHNOLOGY
1. The authority citation for 48 CFR part 39 continues to read as follows: Authority: 40 U.S.C. 121(c); 10U.S.C. chapter 137; and 42 U.S.C. 2473(c).
2. Amend section 39.101 by revising paragraph (d) to read as follows:
39.101 Policy.
* * * * *

(d) In acquiring information technology, agencies shall include the appropriate IT security policies and requirements, including use of common security configurations available from the NIST’s website at http://checklists.nist.gov. Agency contracting officers should consult with the requiring official to ensure the appropriate standards are incorporated.

Translated into English, what this means is that the NIST configurations checklists are coded into law for Government IT purchases.

This carries a HUGE impact to both the Government and contractors.  For the Government, they just outsourced part of their security to Dell and HP, whether they know it or not.  For the desktop manufacturers, they just signed up to learn how FDCC works if they want some of the Government’s money. 

Remember back in the halcyon days of FDCC when I predicted that one of the critical keys to success for FDCC was to be able to buy OEM desktops with the FDCC images on them.  It’s slowly becoming a reality.

Oh what’s that, you don’t sell desktops?  Well, this applies to all NIST configuration checklists, so as NIST adds to the intellectual property in the checklists program, you get to play too.  Looking at the DISA STIGs as a model, you might end up with a checklist for literally everything.

So as somebody who has no relation to the US Federal Government, you must be asking by now how you can ride the FDCC wave?  Here’s Rybolov’s plan for secure desktop world domination:

• Wait for the government to attain 60-80% FDCC implementation
• Wait for desktops to have an FDCC option for installed OS
• Review your core applications on the FDCC compatibility list
• Adopt FDCC as your desktop hardening standard
• Buy your desktop hardware with the image pre-loaded
• The FDCC configuration rolls uphill to be the default OS that they sell
• ?????
• Profit!

And the Government security trickle-down effect keeps rolling on….

Cynically, you could say that the OMB memos as of late (FDCC, DNSSEC) are very well coached and that OMB doesn’t know anything about IT, much less IT security.  You probably would be right, but seriously, OMB doesn’t get paid to know IT, they get paid to manage and budget, and in this case I see some sound public policy by asking the people who do know what they’re talking about.

While we have on our cynical hats, we might as well give a nod to those FISMA naysayers who have been complaining for years that the law wasn’t technical/specific enough.   Now we have very static checklists and the power to decide what a secure configuration should be has been taken out of the hands of the techies who would know and given to research organizations and bureaucratic organizations who have no vested interest in making your gear work.

Lighthouse From AFAR photo by Kamoteus.

• Comments on SCAP 2008
• No, FISMA Doesn’t Require That, Silly Product Pushers
• Federated Vulnerability Management
• Current Government Security Initiatives
• When the News Breaks, We Fix it…

This super secret security control is from the unpublished control catalog of an agency we would be foolish to name here.  Oh, darn, you talked me into it, the agency is the Director of National Intelligence – Extralegal Ventures to Rectify Information Technology Hacks, Incursions and Numbskulls Gabbing (DNI-EVRYTHING):

PS-1337 PERSONNEL SANITIZATION AND DISPOSAL

Control:
The organization sanitizes information system personnel prior to disposal or release for burial.

Supplemental Guidance:
Sanitization is the process used to remove information from information system personnel such that there is reasonable assurance, in proportion to the confidentiality of the information, that the information cannot be retrieved, recovered or extraordinarily renditioned. Sanitization techniques, including clearing, purging, and destroying personnel information, prevent the disclosure of organizational information to unauthorized individuals when personnel are disposed. The organization uses its discretion on sanitization techniques and procedures for personnel containing information deemed to be in the public domain or publicly releasable, or deemed to have no adverse impact on the organization or individuals if released for reuse or disposed. The Black Operations For the Homeland (BOFH) provides personnel sanitization guidance and maintains a listing of approved sanitization procedures in their publication “Leave No Incriminating Evidence (or Where Jimmy Hoffa Went) Directive and BBQ Cookbook”.

Control Enhancements:
(1) The organization tracks, documents, and verifies personnel sanitization and disposal actions.
(2) The organization periodically tests sanitization equipment and procedures to verify correct performance.
(3) The organization employs personnel sanitizers (‘cleaners’) who bear an uncanny resemblance to either Harvey Keitel or Jean Reno to perform ad hoc personnel sanitization procedures.
(4) Lbh fubhyq arire gehfg EBG13 rapelcgvba be chg lbhe snvgu va pbafcvenpl gurbevrf. (ROT13 Super-Encrypted)

LOW: Not Selected  MOD: PS-1337(1)(2)  HIGH: PS-1337(1)(2)(3)  MAJESTIC12: PS-1337(1)(2)(3)(4)

• Workin’ for the ‘Counters: an Analysis of my Love-Hate Relationship with the CPAs
• Transparency in Government: Just Give us the Data!
• Introducing the NoVa InfoSec Portal
• Communicating the Value of Security Seminar Preview
• Yet More Security Controls You Won’t See in SP 800-53

I like SmartBuy, I’ve talked about it before, it’s a software bulk-purchase program sponsored by GSA. The more types of software products they buy, the better for the people who need to depend on this stuff.

So I’m doing my usual beginning-of-the-week upcoming contracts perusal and something interesting caught my eye:  GSA is looking for “Situational Awareness and Incident Response” (SAIR) software to do a blanket purchase agreement for SmartBuy.

What they mean by SAIR (according to the pre-RFP information) is the following:

• Baseline Configuration Management
• Network Mapping
• Vulnerability Management

Really, think something along the lines of FDCC/SCAP-aware tools to manage IT assets.  Not sure how the incident response piece fits in, but OK, I’ll go along with you here.  Makes sense if you stop and think about it–we have a FDCC mandate from OMB, and now we’re looking for the tools to help with it–I mentioned that FDCC without automation was futile almost 9000 years ago.

I know I have blog readers who make similar software, drop me a message if you need more details.

And for my daily dose of snarkiness:  it’s good to see how GSA has come such a long way in my life from being just the provider of skillcraft pens and simple green.  =)

• Comments on SCAP 2008
• Current Government Security Initiatives
• NIST and SCAP; Busting a cap on intruders Part 1
• Ed Bellis’s Little SCAP Project
• Some Words From a FAR

Pet peeve of just about every CISO in existance:  the so-called “audit requirements”.  What they really mean to say is “It’s on the checklist, so it has to be true, just do what I say”.

Without traceability to the actual requirement, items on a checklist are just that: items on a checklist.

Anyway, on to the lulz:

• Auditors and LULZ
• IKANHAZFIZMA Tackles the Consensus Audit Guidelines
• LOLCATS Take on MS08-67
• Continuous Monitoring with LOLCATS
• The Authorizing Official and the Lolcat