OK, since everybody seems to think that FISMA is some evil thing that needs reform, this is the version of events on “Planet Rybolov”:

Goals to surviving FISMA, based on all the criticisms I’ve read:

• Reduce paperwork requirements. Yes, some is needed.  Most is not.
• Reduce cost. There is much repetition in what we’re doing now, it borders on fraud, waste, and abuse.
• Increase technical effectiveness. IE, get from the procedural and managerial tasks and get down into the technical parts of security.

“Uphold our Values-Based Compliance Culture photo by kafka4prez.

So now, how do you keep from letting FISMA cripple you or turn into death-by-compliance:

• Prioritize. 25% of your controls need to not fail 100% of the time.  These are the ones that you test in-depth and more frequently.  Honestly, how often does your risk assessment policy get updated v/s your patch management?  Believe it or not, this is in SP 800-53R3 if you interpret it in the correct context.  More importantly, do not let your auditors dictate your priorities.
• Use common controls and shared infrastructure. Explicitly tell your system owners and ISSOs what you are providing as the agency CISO and/or the GSS that they are riding on.  As much as I hate meetings, if you own a General Support System (GSS), infrastructure (LAN/WAN, AD Forest, etc), or common controls (agency-wide policy, budget, Security Operations Center, etc), you have a fiduciary, legal, and moral obligation to get together with your constituency (the people who rely on the security you provide) and explain what it is you provide and allow them to tell you what additional support they need.
• Share Assessment Results. I’m talking about results from service providers with other agencies and systems.  We’re overtesting on the high-level stuff that doesn’t change and not on the detailed stuff that does change.  This is the nature of security assessments in that you start at the top and work your way down into the details, only most assessments don’t get down into the details because they’re busy reworking the top-level stuff over and over again.  Many years ago as a contractor managing infrastructure that multiple agencies used, it was unbelievably hard to get one agency to allow me to share security documents and assessment results with other agencies.  Shared assessment results mean that you can cut through the repetitious nature of what you’re doing and progressively get deeper into the technical, frequently-changing security aspects.
• Simplify the Paperwork. Yes, you still need to document what you’re doing, but the days of free-text prose and being graded on grammar and punctuation need to be over.  Do the controls section of System Security Plans as a Requirement Traceability Matrix.  More important than that, you need to go by-control by-component.  If you are hiring contractors and their job is to do copypasta directly from NIST documents and change the pronouns and tenses, you’re doing it wrong.  Don’t stand for that in your security policy or anything else that you do.
• Automate Wherever Possible. Note that the controls that change frequently and that need to not fail usually fit into this group.  It’s one of those “Things that make Rybolov go ‘Hmmmm'”.  Technology and automation provide both the problem and the solution.  Also see my first point up above.
• Fire 50% of Your Security Staff. Yes, I’m serious.  Those people you didn’t need anyway, primarily because they’re violating all the points I’ve made so far.  More importantly, 25 clueless people can mess things up faster than 5 clueful people can fix them, and that’s a problem for me.  Note that this does not apply to @csoandy, his headcount is A-OK.

The incredible thing to me is that this stuff is already there.  NIST writes “hooks” into their Special Publications to allow the smart people the room to do all these things.

And now the part where I hop up on my soapbox:  reforming FISMA by new legislation will not make any achievements above and beyond what we have today (with the exception of creating a CISO-esque position for the Exective Branch) because of the nature of audit and compliance.  In a public policy sense, the more items you have in legislation, the more the audit burden increases and the amount of repetition increases, and the amount of nonsense controls (ie, AntiVirus for Linux servers) increases.  Be careful what you ask for, you just might get it.

• “Machines Don’t Cause Risk, People Do!”
• Security Assessments as Fraud, Waste, and Abuse
• GAO’s 5 Steps to “Fix” FISMA
• When the Feds Come Calling
• Observations on SP 800-37R1

There are a couple definitions for “darknet”, all of them valid for this lol.

• Incident Response and Lolcats
• LOLCATS: Defending our Cyber-Turf
• IKANHAZFIZMA and Transparency
• Aurora and LOLCATS
• Snowmageddon Meets the IKANHAZFIZMA Lolcats

A couple of weeks ago I went to the NIST Cloud Conference for the afternoon security sessions.  You can go grab the slides off the conference site.  Good stuff all around.

Come to think of it, I haven’t blogged about FedRAMP, maybe it’s time to.

FedRAMP is a way to do security authorization (formerly certification and accreditation, get with the times, man) on a cloud then let tenant projects use that authorization.  Hmmm, sounds like…. a General Support System with common controls and Major Applications that inherit those controls.  This isn’t really anything new, just the “bread and butter” security management concepts scoped to a cloud.  Basically what will happen with FedRAMP is that they have 3 standards: DoD, DHS, and GSA (most stringent first) and cloud providers get authorized against that standard.  Then when a project wants to build on that cloud, they can use that authorization for their own authorization package.

All things considered, FedRAMP is an awesome idea.  Now if we can get the holdout agencies to actually acknowledge their internal common controls, I’ll be happy–the background story being that some number of months ago I was told by my certifier that “we don’t recognize common controls so even though you’re just a simple web application you have to justify every control even if it’s provided to you as infrastructure.”  No, still not bitter at all here, but I digress….

And then there are the pieces that I haven’t seen worked out yet:

• Mechanism of Sharing: As a service provider, it’s hard enough to keep one agency happy.  Add in 5 of them and it gets nearly impossible.  This hasn’t really been figured out, but in Rybolov’s small, myopic world, a panel of agencies owning an authorization for a cloud provider means that the cloud never gets authorized.  The way this has been “happening in the wild” is that one agency owns the authorization and all the other agencies get the authorization package from that agency.
• Using FedRAMP is Optional: An agency or project can require their own risk assessment and authorization even though a FedRAMP one is available.  This means that if the agency’s auditors don’t understand the process or the “risk monkeys” (phrase courtesy of My Favorite Govie) decree it, you lose any kind of cost savings and time savings that you would get by participating in FEDRAMP.
• Cloud Providers Rule the Roost: Let’s face it, as much as the Government wants to pretend that the cloud providers are satisfying the Government’s security requirements, we all know that due to the nature of catalogs of controls and solution engineering, the vendor here has the advantage.  Nothing new, it’s been happening that way with outsourcing, only now it’s immediately evident.  Instead of trying to play ostrich and stick our heads in the sand, why don’t we look at the incentives for the cloud providers and see what makes sense for their role in all this.
• Inspector General Involvement: I don’t see this happening, and to be honest, this scares the hell out of me.  Let me just invoke Rybolov’s Law: “My solution is only as good as my auditor’s ability to understand it.”  IE, if the IGs and other auditors don’t understand FedRAMP, you don’t really have a viable solution.

The Big Ramp photo by George E. Norkus.  FedRAMP has much opportunity for cool photos.

• Reinventing FedRAMP
• Cloud Computing and the Government
• FedRAMP: It’s Here but Not Yet Here
• Clouds, FISMA, and the Lawyers
• How to Not Let FISMA Become a Paperwork Exercise

Refs:

• I Accidentally
• Marcus Ranum’s Ultimate Firewall

• LOLCATS Take on MS08-67
• Redundant Lolcats
• Lolcats Protect the End Users
• LOLCATS and #CapSec
• LOLCATS and Firewalls

A few weeks back I read an article on an apparent shift in emphasis in government security… “OMB outlines shift on FISMA” take a moment to give it a read. I’ll wait….

That was followed by NASA’s “bold move” to change the way they manage risk…

Once again the over-emphasis and outright demagoguery on “compliance,” “FISMA reports,” “paper exercises,” and similar concepts that occupy our security geek thoughts have not given way to enlightenment. (At least “compliancy” wasn’t mentioned…) I was saddened by a return to the “FISMA BAD” school of thought so often espoused by the luminaries at SANS. Now NASA has leapt from the heights… At the risk of bashing Alan Paller yet again, I am often turned off by the approach of “being able to know the status of every machine at every minute, ” – as if machines by themselves cause bad security… It’s way too tactical (incorrect IMHO) and too easy to make that claim.

Hence the title of this rant – Machines don’t cause risk, people do!

The “people” I’m talking about are everyone from your agency director, down to the lowliest sysadmin… The problem? They may not be properly educated or lack the necessary skills for their position – another (excellent) point brought forth in the first article. Most importantly, even the most seasoned security veteran operating without a strategic vision within a comprehensive security program (trained people, budget, organizational will, technology and procedures) based upon the FISMA framework will be doomed to failure. Likewise, having all the “toys” in the world means nothing without a skilled labor force to operate them and analyze their output. (“He who dies with the most toys is still dead.”) Organizations and agency heads that do not develop and support a comprehensive security program that incorporates the NIST Risk Management Framework as well as the other facets listed above will FAIL. This is nothing new or revolutionary, except I don’t think we’ve really *done* FISMA yet. As I and others have said many times, it’s not about the paper, or the cost per page – it’s about the repeatable processes — and knowledgeable people — behind what the paper describes.

I also note the somewhat disingenuous mention of the risk management program at the State Department in the second article… As if that were all State was doing! What needs to be noted here is that State has approached security in the proper way, IMHO — from a Strategic, or Enterprise level. They have not thrown out the figurative baby with the bath water by dumping everything else in their security program in favor of the risk scoring system or some other bright, shiny object. I know first-hand from having worked with many elements in the diplomatic security hierarchy at State – these folks get it. They didn’t get to the current level of goodness in the program by decrying (dare I say whining about?) “paper.” They made the organizational commitment to providing contract vehicles for system owners to use to develop their security plans and document risk in Plans of Action and Milestones (POA&Ms). Then they provided the money to get it done. Is the State program a total “paragon of virtue?” Probably not, but the bottom line is that it’s an effective program.

Mammoth Strategy, Same as Last Year image by HikingArtist.com.

Desiring to know everything about everything may seem to some to be a worthy goal, but may be beyond many organization’s budgets. *Everything* is a point in time snapshot, no matter how many snapshots you take or how frequently you take them. Continuous, repeatable security processes followed by knowledgeable, responsible practitioners are what government needs. But you cannot develop these processes without starting from a larger, enterprise view. Successful organizations follow this–dare I say it–axiom whether discussing security governance, or system administration.

Government agencies need to concentrate on developing agency-wide security strategies that encompass, but do not concentrate on solely, what patch is on what machine, and what firewall has which policy. Likewise, system POA&Ms need to concentrate on higher-level strategic issues that affect agencies — things like changes to identity management schemes that will make working from home more practical and less risky for a larger percentage of the workforce. Or perhaps a dashboard system that provides the status of system authorization for the agency at-a-glance. “Burying your head in a foxhole” —becoming too tactical — is akin to burying it in the sand, or like getting lost in a bunch of trees that look like a forest. When organizations behave this way, everything becomes a threat, therefore they spray their resource firepower on the “threat of the day, or hour.”

An organization shouldn’t worry about patching servers if its perimeter security is non-existent. Developing the larger picture, while letting some bullets strike you, may allow you recognize threats, prioritize them, potentially allowing you to expend minimal resources to solve the largest problem. This approach is the one my organization is following today. It’s a crawl first, then walk, then run approach. It’s enabled management to identify, segregate, and protect critical information and resources while giving decision-makers solid information to make informed, risk-based decisions. We’ll get to the patches, but not until we’ve learned to crawl. Strangely, we don’t spend a lot of time or other organizational resources on “paper drills” — we’re actively performing security tasks, strategic and tactical that follow documented procedures, plans and workflows! Oh yes, there is the issue of scale. Sorry, I think over 250 sites in every country around the world, with over 62 different government customers tops most enterprises, government or otherwise, but then this isn’t about me or my organization’s accomplishments.

In my view, professional security education means providing at least two formal paths for security professionals – the one that SANS instantiates is excellent for administrators – i.e., folks operating on the tactical level. I believe we have these types of security practitioners in numbers. We currently lack sufficient seasoned professionals – inside government – who can approach security strategically, engaging agency management with plans that act both “globally” and “locally.” Folks like these exist in government but they are few. Many live in industry or the contractor space. Not even our intelligence community has a career path for security professionals! Government as a whole lacks a means to build competence in the security discipline. Somehow government agencies need to identify security up-and-comers within government and nurture them. What I’m calling for here is a government-sponsored internal mentorship program – having recognized winners in the security game mentor peers and subordinates.

Until we security practitioners can separate the hype from the facts, and can articulate these facts in terms management can understand and support, we will never get beyond the charlatans, headline grabbers and other “self-licking ice cream cones.” Some might even look upon this new, “bold initiative” by NASA as quitting at a game that’s seen by them as “too hard.” I doubt seriously that they tried to approach the problem using a non-academic, non-research approach. It needed to be said. Perhaps if the organization taking the “bold steps” were one that had succeeded at implementing the NIST guidance, there might be more followers, in greater numbers.

Perhaps it’s too hard because folks are merely staring at their organization’s navel and not looking at the larger picture?

Lastly, security needs to be approached strategically as well as tactically. As Sun Tzu said, “Tactics without strategy is the noise before defeat.”

• A Funny Thing Happened Last Week on Capital Hill
• How to Not Let FISMA Become a Paperwork Exercise
• When the Feds Come Calling
• Ooh, “The Word” is out on S 3474
• Some Comments on SP 800-39

As I’m going through a wide variety of control frameworks in a managed services/cloud environment, I’m reminded of how controls work when you’re a service provider.  Mentally, I break them down into four “buckets”:

• Controls that I provide to all customers as part of my baseline. In other words, these are things that I do for all of my customers because it’s either part of the way that I do business or it makes sense to do it once and scale it out to everybody.  Typically these are holistic information security program things (ISO 17799/27001/27002 or similar) matched up with my service-delivery architecture.
• Controls that I provide as an add-on service. Not all of my customers need these but I want to offer them to my customers to help them with their security program.  Usually these are services and products supporting a regulatory framework specific to one industry:  PCI-DSS, FISMA, GLBA, etc fit in here if my market is not exclusive to customers governed by those regulations.  In order to keep the base cost for the other customers low, these aren’t included in the base service but are available for a price.
• Controls that I am planning on building. I don’t have them yet but they’re on my roadmap.  Sometimes this is how I get into new markets by building the products and services that match up against the regulatory framework for that market, then build to that as a specification.
• Controls that I will not provide. Maybe this control doesn’t apply to my products and service (The “We don’t actually own a Windows/HP-UX/AIX server” problem).  Maybe the controls framework didn’t scope my solutions into its assumptions.  Maybe the economics of this didn’t work out.  Maybe I don’t provide this because it’s dishonest for both myself and you as my customer for me to say I provide this–think along the lines of accepting risk on your behalf which puts me into a conflict of interest.  This is why any vendor who says they provide 100% compliancy against FooFramework is lying.

Transparency ties it all together.  The good providers will tell you upfront which controls belong in which buckets.

Tool Bucket photo by tornatore.

• Reinventing FedRAMP
• Security Assessment Economics
• When the Feds Come Calling
• How to Not Let FISMA Become a Paperwork Exercise
• NIST Cloud Conference Recap