OK, now for the control-by-control analysis of the 20 Critical Security Controls.  This is part 2.  Look here for the first installment.  Read part 3 here.

Critical Control 1: Inventory of Authorized and Unauthorized Devices. This is good: get an automated tool to do IT asset discovery.  Actually, you can combine this with Controls 2, 3, 4, 11, and 14 with some of the data center automation software–you know the usual suspects, just ask your ops folks how you get in on their tools.  This control suffers from scope problems because it doesn’t translate down to the smaller-system scale:  if I have a dozen servers in an application server farm inside of a datacenter, I’ll usually know if anybody adds something.  The metric here (detect all new devices in 24 hours) “blows goats” because you don’t know if you’re detecting everything.  A better test is for the auditor to do their own discovery scans and compare it to the list in the permanent discovery tool–that would be validation that the existing toolset does work–with a viable metric of “percentage of devices detected on the network”.  The 24 hour metric is more like a functional requirement for an asset discovery tool.  And as far as the isolation of unmanaged assets, I think it’s a great idea and the way things should be, except for the fact that you just gave us an audit requirement to implement NAC.

Critical Control 2: Inventory of Authorized and Unauthorized Software. Sounds like the precursor to whitelisting.  I think this is more apropos to the Enterprise unless your system is the end-user computing environment (laptops, desktops).  Yes, this control will help with stuff in a datacenter to detect when something’s been pwned but the real value is out at the endpoints.  So yes, not happy with the scope of this control.  The metric here is as bad as for Control 1 and I’m still not happy with it.  Besides, if you allow unauthorized software to be on an IT device for up to 24 hours, odds are you just got pwned.  The goal here should be to respond to detected unauthorized software within 24 hours.

Critical Control 3: Secure Configurations for Hardware and Software on Laptops, Workstations, and Servers. This is actually a good idea, provided that you give me a tool to apply the settings automagically because manual configuration sucks.  I think it’s about a dozen different controls all wrapped into one, it’s just trying to do too much in one little control.  The time-based metric for this control is really bad, it’s like watching a train wreck.  But hey, I’ll offer up my own: percentage of IT assets conforming to the designated configuration.  It’s hinted at in the implementation guide, make it officially the metric and this might be a control I can support.

Critical Control 4: Secure Configurations for Network Devices such as Firewalls, Routers, and Switches. This is basically Control 3 for network devices.  The comments there also apply here.

Critical Control 5: Boundary Defense. This control is too much stuff crammed into one space.  As a result, it’s not concise enough to be implemented–it’s all over the map.  In fact, I’ll go as far as to say that this isn’t really one control, it’s a control theme with a ton of controls inside of it.  The “audit requirements” here are going to utterly kill me as a security manager because there is so much of a disparity between the control and the actual controls therein.

Critical Control 6: Maintenance, Monitoring, and Analysis of Audit Logs. Some of this control should be part of Controls 3 and 4 because, let’s be honest here, you’re setting up logging on devices the way that the hardening guide says you should.  The part that’s needed in this control is aggregation of logs and review of logs–get them off all the endpoints and into a centralized log management solution.  This is mentioned as the last “advanced” implementation technique but if you’re operating a modern Enterprise, I don’t see how you can get the rest of the implementation done without some kind of SIEM piece.   I just don’t get the metric here, again with the 24 hours.  How about “percentage of devices reporting into the SIEM”?  Yeah, that’s the easy money here.  The testing of this control makes me do a facepalm:  “At a minimum the following devices must be tested: two routers, two firewalls, two switches, ten servers, and ten client systems.”  OK, we’ve got a LAN/WAN with 15000 endpoints and that’s all we’re going to test?

Critical Control 7: Application Software Security. You keep using those words, I do not think they mean what you think they mean.  Application security is a whole different world and 20 CSC doesn’t even begin to scratch the surface of it.  Oh, but guess what?  It’s a tie-in to the 25 Most Dangerous Programming Errors which is about all this control is:  a pointer to a different project.  The metric here is very weak because it’s not tied back to the actual control.

Critical Control 8: Controlled Use of Administrative Privileges. This should be part of Controls 3 and 4, along with something about getting an Identity and Access Management system so that you have one ID repository.  I know this is a shocker to you, but the metric here sucks.

Critical Control 9: Controlled Access Based on Need to Know. This is a great idea, but as a control it’s too broad to achieve, which is why the 20 CSC were created in the first place.  What do we really want here?  Network share ACLs are mentioned, which is a control in itself, but the rest of this is hazy and leaves much room for interpretation.  Cue “audit requirements” and the part where Rybolov says “If it’s this hazy, it’s not really a standard, it’s a guideline that I shouldn’t be audited against.

Critical Control 10: Continuous Vulnerability Assessment and Remediation. All-in-all, not too bad.  I would suggest “Average time to resolve scan findings” here as a metric or even something as “hoakey” as the FoundScan metric just to gauge overall trends.

Arm Control photo by Crotchsplay.

Critical Control 11: Account Monitoring and Control. Haven’t we seen this before?  Yep, this should be incorporated into Controls 8, 3, and 4.  However, periodic account reviews are awesome if you have the patience to do it.

Critical Control 12: Malware Defenses. OK, this isn’t too bad.  Once again, the metric sucks, but I do like some of the testing steps.  The way I would test this is to compare our system inventory with my total list of devices.  A simple diff later, we have a list of unmanaged devices.

Critical Control 13: Limitation and Control of Network Ports, Protocols, and Services. Host firewalls was not what I thought of… I’m thinking more like firewalls and network segmentation where you have to get change control approval to add a firewall rule.  As far as the host setup, this should be part of Control 3.

Critical Control 14: Wireless Device Control. Not bad, but this should be dumped into a technical standard that you use like a hardening guide.  Metric here still sucks, but I don’t really need to say this again… oh wait, I just did.

Critical Control 15: Data Loss Prevention. Puh-lease.  I’ll be the first to admit, I’m a big believer in DLP done right, and that it’s an awesome tool to solve some of the unique .  But I don’t think that the market is mature enough to add it into your catalog of controls.  Also this will fall flat on its face if your system is just a web application cluster:  DLP addresses the endpoints (desktops, laptops, mobiles) and the outbound gateways (email, web, etc).  The problem with this control is that if you don’t buy and implement a full DLP solution (cue Rich Mogull and his DLP guide), there isn’t anything else that has a similar capability.  This is one of those controls where the 800-53 mapping gets really creative–Good Ship Lollipop Creative because we’re tapdancing around the issue that DLP-type solutions aren’t specifically required in 800-53.

These controls don’t have automated ways to implement and test them:

Critical Control 16: Secure Network Engineering. This control is a steaming crater.  It’s very much a guideline instead of an auditable standard.

Critical Control 17: Penetration Tests and Red Team Exercises. Not bad.  Still too easy to shop around for the bargain-basement penetration test team.  But yeah, pretty good overall.

Critical Control 18: Incident Response Capability. Good control.  Hard to test/audit except to look at after-incident reports.

Critical Control 19: Data Recovery Capability. Not bad here.  Not real COOP/DR/ITCP but about on par with typical controls frameworks.

Critical Control 20: Security Skills Assessment and Appropriate Training to Fill Gaps. Good idea.  Hard to implement without something like 8570.10 to give you a matrix by job position.  You want to change the world here, give your own mapping in the control.

• Opportunity Costs and the 20 Critical Security Controls
• 20 Critical Security Controls: What They Did Right and What They Did Wrong
• Security Assessments as Fraud, Waste, and Abuse
• Federated Vulnerability Management
• The Guerilla CISO Rants: Don’t Write a System Security Plan

This is a multi-post series.  You are at post 1.  Read post 2 here.  Read Post 3 here.

This post begins with me.  For the past hour or so I’ve been working on a control-by-control objective analysis of SANS 20 Critical Security Controls.  This is a blog post I’ve had sitting “in the hopper” for 9 months or so.  And to be honest, I see some good things in the 20 CSC literature.  I think that, from a holistic perspective, the 20 CSC is an attempt at creating a prioritization of this huge list of stuff that I have to do as an information security officer–something that’s really needed.  I go into 20 CSC with a very open mind.

Then I start reading the individual controls.  I’m a big believer in Bottom-Line-Up-Front, so let me get my opinion out there now: 20 Critical Security Controls is crap.  I’m sorry John G and Eric C.  Not only is 20 CSC bad from a perspective of controls, metrics, and auditing tests, but if it’s implemented across the Government, it will be the downfall of security programs.  I really believe this.

Now on to the rationale….

Opportunity Costs. I can’t get that phrase out of my head.  And I’m not talking money just yet–I’m talking time.  See, I’m an IT security guy working for a contractor supporting a Government agency–just like 75% of the people out there.  I have a whole bunch of things to do–both in the NIST guidelines and organizational policy.  If you add anything else to the stack without taking anything away,  all you’ve done is to dilute my efforts.  And that’s why I can’t support 20 CSC–they’re an unofficial standard that does not achieve its stated primary goal of reducing the amount of work that I have to do.  I know they wanted to create a parallel standard focusing on technical controls but you have to have one official standard because if it’s not official, I don’t have to do it and it’s not really a standard anymore, it’s it?

Scoping Problems. We really have 2 tiers inside of an agency that we need to look at: the Enterprise and the various components that depend on the Enterprise.  Let’s call them… general support systems and major applications.  Now the problem here is that when you make a catalog of controls, some controls are more applicable to one tier than the other.  With 20 CSC, you run the classic blunder of trying to reinvent the wheel for every small system that comes along.

Threat Capabilities != Controls. And this is maybe the secret why compliance doesn’t work like we think it will.  In a nice theoretical world, it’s a threat-vulnerability-countermeasure coupling and the catalog of controls accounts for all likely threats and vulnerabilities.  Well, it doesn’t work that way:  it’s not a 1-to-1 ratio.  Typical security management frameworks start from a regulatory perspective and work their way down to technical details while what we really want to do is to build controls based on the countermeasures that we need.  So yeah, 20 CSC has the right idea here, the problem is that it’s a set of controls created by people who don’t believe in controls–the authors have the threat and vulnerability piece down and some of the countermeasures but they don’t understand how to translate that into controls to give to implementers and their auditors.  The 20 CSC guys are smart, don’t get me wrong, but I can’t help but get the feeling that they don’t understand how the “rest of the world” is getting their job done out there in the Enterprise.

The Mapping is Weak. There is a traceability matrix in the 20 CSC to map each control back to NIST controls.  It’s really bad, mostly because the context of 800-53 controls doesn’t extend into 20 CSC.  I have serious heartburn with how this is presented inside the agencies because we’re not really doing audits using the 20 CSC, we’re using the mapping of NIST controls with a weird subtext and it’s a “voluntary assessment” not an audit.

Guidelines?!?!?! This is basic stuff.  If it’s something you audit against, it *HAS* to be a standard.  Guidelines are recommendations and can add in more technique and education.  Standards are like hard requirements, they only work if they’re narrowly-scoped, achievable, and testable.  This isn’t specific to 20 CSC, the NIST Risk Management Framework (intended to be a set of guidelines also) suffers from this problem, too.  However, if your intent is to design a technical security and auditing standard, you need to write it like a standard.  While I’m up on a soapbox, for the love of $Diety, quit calling security controls “requirements”.

Auditor Limitations. Let’s face it, how do I get an auditor to add an unmanaged device to the network and know if we’ve detected it or not.  This is a classic mistake in the controls world:  assuming that we have enough people with the correct skillsets who can conduct intrusive technical tests without the collusion of my IT staff.

And the real reason why I dislike the 20 Critical Security Controls:

Introduction of “Audit Requirements”. One of the chief criticisms of the NIST Risk Management Framework is that the controls are not specific enough.  20 CSC falls into this trap of nonspecificity (Controls 7, 8, 9, and 15, I’m talking to you) and is not official guidance–a combination that means that my auditor has just added requirements to my workload simply because of how they interpret the control.  This is very dangerous and why I believe 20 CSC will be the end of IT security as we know it.

In future posts (I had to break this into multiple segments):

• Control-by-control analysis
• What 20 CSC got right (Hey, some of it is good, just not for the reasons that it’s supposed to be good)

SA-2 “Guideline” photo by cliff1066™.

• 20 Critical Security Controls: What They Did Right and What They Did Wrong
• 20 Critical Security Controls: Control-by-Control
• Workin’ for the ‘Counters: an Analysis of my Love-Hate Relationship with the CPAs
• Your Security “Requirements” are Teh Suxxorz
• How to Not Let FISMA Become a Paperwork Exercise

A little presentation I did for NoVA Hackers.  Basic intent was to be more workshop than something more formal and to give everybody the tools to do their own experimentation at home.

I even inspired Jack to write a blog post.

Caveat: this has nothing to do with FISMA or Government InfoSec.  =)

Links in the Presentation:

• Zint
• ZXing
• BeeTagg
• Other Readers

Links of interest:

• Code 128
• QR Code
• Data Formatting Fun

• Save a Kitten, Write SCAP Content
• DojoCon 2009 Presentation
• QR Code Temporary Tattoos Howto
• Barcode Hacking Process
• The Accreditation Decision and the Authorizing Official

Every once in a while an opportunity presents itself to affect some real change in federal information security practice.  Now is such a time.  A slew of new NIST documents are being released between now and April.  These are the core NIST documents that describe how to satisfy FISMA.  They include NIST SPs 800-30 Revision 1, 800-39, 800-37 Revision 1 and 800-53A Revision 1. That’s where you come in.

The documents define what federal government practice will look like in the coming years.  If they are flawed then the practice will be flawed.  To prevent stupidity from leaking in when nobody is looking NIST releases the documents as drafts so everyone gets a chance to eyeball them.  First you eyeball, then you comment.  They look at the comments and they fix the flaws.  Fix the flaws now and you don’t live with them later.

The most important document in draft right now is the NIST Special Publication 800-37 Revision 1.  This document describes the central processes involved in the authorization of information systems that support the federal government.  Notice I didn’t say Certification and Accreditation?  That’s because C&A is deader than a sheep at a wolf convention. Want to know what replaces it?  Pick up a copy of NIST SP 800-37r1 FPD, give it a read and send in your comments.

Better yet, consider joining a formal document review process.  I’m leading a team of hale and hearty volunteers at OWASP in a NIST SP 800-37r1 FPD review and we’d love to have you come join the fun.   We’re on a tight schedule so now is the time to act.

Time is short, the comment period for NIST SP 800-37 Revision 1 FPD ends on December 31st, 2009.

• The Guerilla CISO Rants: Don’t Write a System Security Plan
• Observations on SP 800-37R1
• NIST Cloud Conference Recap
• William Jackson on FISMA: It Works, Maybe
• “Machines Don’t Cause Risk, People Do!”

So now that His Esteemed Highness Eric Schmidt has declared privacy dead, our IKANHAZFIZMA team of LOLCATS wants to know if they can resume their usual collection of cellular traffic.

References:
Gawker: Google CEO: Secrets Are for Filthy People

Schneier Blog: My Reaction to Eric Schmidt

Download Squad: Only naughty people should be afraid of Google, says CEO Eric Schmidt

The Register: Google chief: Only miscreants worry about net privacy

• Redundant Lolcats
• Lolcats Coming to you from the Cloud
• Lolcats and QR Codes
• Lolcats Protect the End Users
• Lolcats, Capital Hill, and a Haiku

OK, so it’s been a couple of months of thinking about this thing.  I threw together a rainbow-looking beast that now occupies my spare brain cycles.

Rybolov’s Information Security Management Model

And some peculiarities of the model that I’ve noticed:

Regulation, Compliance, and Governance flows from the top to the bottom.  Technical solutions flow from the bottom to the top.

The Enterprise (Layer 4) gets the squeeze.  But you CISOs out there knew that already, right?  It makes much sense in the typical information security world to focus on layers 3, 4, and 5 because you don’t usually own the top and the bottom of the management stack.

The security game is changing because of legislation at layers 5 and 6.  Think national data breach law.  It seems like the trend lately is to throw legislation at the problems with information security.  The scary part to me is that they’re trying to take concepts that work at layers 3 and 4 and scale them up the model with very mixed results because there isn’t anybody doing studies at what happens above the Enterprise.  Seriously here, we’re making legislation based on analogies.

Typically each layer only knows about the layer above and below it.  This is a serious problem when you have people at layers 5 and 6 trying to create solutions that carry down to layers 1 through 4.

At layers 1 and 2, you have the greatest chance to solve the root causes of security problems.  The big question here is “How do we get the people working at these layers the support that they need?”

• A Layered Model for Massively-Scaled Security Management
• Massively Scaled Security Solutions for Massively Scaled IT
• Professor Rybolov’s Guide to InfoSec and Public Policy Analysis
• Blow-By-Blow on S.773–The Cybersecurity Act of 2009–Part 5
• Blow-By-Blow on S.773–The Cybersecurity Act of 2009–Part 4