Face it, your security requirements suck. I’ll tell you why.  You write down controls verbatim from your catalog of controls (800-53, SoX, PCI, 27001, etc), put it into a contract, and wonder how come when it comes time for security testing, we just aren’t talking the same language.  Even worse, you put in the cr*ptastic “Contractor shall be compliant with FISMA and all applicable NIST standards”.  Yes, this happens more often than I could ever care to count, and I’ve seen it from both sides.

The problem with quoting back the “requirements” from a catalog of controls is that they’re not really requirements, they’re control objectives–abstract representations of what you need in order to protect your data, IT system, or business.  It’s a bit like brain surgery using a hammer and chisel–yes, it might work out for you, but I don’t really feel comfortable doing it or being on the receiving end.

And this is my beef with the way we manage security controls nowadays.  They’re not requirements, functionally they’re a high-level needs statement or even a security concept of operations.  Security controls need to be tailored into real requirements that are buildable, testable, measurable, and achievable.

Requirements photo by yummiec00kies.  There’s a social commentary in there about “Single, slim, and pleasant looking” but even I’m afraid to touch that one. =)

Did you say “Wrecks and Female Pigs’? In the contracting world, we have 2 vehicles that we use primarily for security controls: Statements of Work (SOW) and Engineering Requirements.

• Statements of Work follow along the lines of activities performed by people.  For instance, “contractor shall perform monthly 100% vulnerability scanning of the $FooProject.”
• Engineering Requirements are exactly what you want to have build.  For instance, “Prior to displaying the login screen, the application shall display the approved Generic Government Agency warning banner as shown below…”

Let’s have a quick exercise, shall we?

What 800-53 says: The information system produces audit records that contain sufficient information to, at a minimum, establish what type of event occurred, when (date and time) the event occurred, where the event occurred, the source of the event, the outcome (success or failure) of the event, and the identity of any user/subject associated with the event.

How It gets translated into a contract: Since it’s more along the lines of a security functional requirement (ie, it’s a specific functionality not a task we want people to do), we brake it out into multiple requirements:

The $BarApplication shall produce audit records with the following content:

• Event description such as the following:
  • Access the $Baz subsystem
  • Mounting external hard drive
  • Connecting to database
  • User entered administrator mode
• Date/time stamp in ‘YYYY-MM-DD HH:MM:SS’ format;
• Hostname where the event occured;
• Process name or program that generated the event;
• Outcome of the event as one of the following: success, warn, or fail; and
• Username and UserID that generated the event.

For a COTS product (ie, Windows 2003 server, Cisco IOS), when it comes to logging, I get what I get, and this means I don’t have a requirement for logging unless I’m designing the engineering requirements for Windows.

What 800-53 says: The The organization configures the information system to provide only essential capabilities and specifically prohibits and/or restricts the use of the following functions, ports, protocols, and/or services: [Assignment: organization-defined list of prohibited and/or restricted functions, ports, protocols, and/or services].

How It gets translated into a contract: Since it’s more along the lines of a security functional requirement, we brake it out into multiple requirements:

The $Barsystem shall have the software firewall turned on and only the following traffic shall be allowed:

• TCP port 443 to the command server
• UDP port 123 to the time server at this address
• etc…..

If we drop the system into a pre-existing infrastructure, we don’t need firewall rules per-se as part of the requirements, what we do need is a SOW along the following lines:

The system shall use our approved process for firewall change control, see a copy here…

So what’s missing, and how do we fix the sorry state of requirements?

This is the interesting part, and right now I’m not sure if we can, given the state of the industry and the infosec labor shortage:  we need security engineers who understand engineering requirements and project management in addition to vulnerability management.

Don’t abandon hope yet, let’s look at some things that can help….

Security requirements are a “best effort” proposition.  By this, I mean that we have our requirements and they don’t fit in all cases, so what we do is we throw them out there and if you can’t meet the requirement, we waiver it (live with it, hope for the best) or apply a compensating control (shield it from bad things happening).  This is unnerving because what we end up doing is arguing all the time over whether the requirements that were written need to be done or not.  This drives the engineers nuts.

It’s a significant amount of work to translate control objectives into requirements.  The easiest, fastest way to fix the “controls view” of a project is to scope out things that are provided by infrastructure or by policies and procedures at the enterprise level.  Hmmm, sounds like explicitly stating what our shared/common controls are.

You can manage controls by exclusion or inclusion:

• Inclusion:  We have a “default null” for controls and we will explicitly say in the requirements what controls you do need.  This works for small projects like standing up a pair of webservers in an existing infrastructure.
• Exclusion:  We give you the entire catalog of controls and then tell you which ones don’t apply to you.  This works best with large projects such as the outsourcing of an entire IT department.

We need a reference implementation per technology.  Let’s face it, how many times have I taken the 800-53 controls and broken them down into controls relevant for a desktop OS?  At least 5 in the last 3 years.  The way you really need to do this is that you have a hardening guide and that is the authoritative set of requirements for that technology.  It makes life simple.  Not that I’m saying deviate from doctrine and don’t do 800-53 controls and 800-53A test procedures, but that’s the point of having a hardening guide–it’s really just a set of tailored controls specific to a certain technology type.  The work has been done for you, quit trying to re-engineer the wheel.

Use a Joint Responsibilities Matrix.  Basically this breaks down the catalog of controls into the following columns:

• Control Designator
• Control Title
• Provided by the Government/Infrastructure/Common Control
• Provided by the Contractor/Project Team/Engineer

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One of the best things about being almost older than dirt is that I’ve seen several cycles within the security community.  Just like fashion and ladies’ hemlines, if you pay attention long enough, you’ll see history repeat itself, or something that closely resembles history.  Time for a short trip “down memory lane…”

In the early days of computer security, all eyes were fixed on Linthicum and the security labs associated with the NSA.  In the late 80’s and early 90’s the NSA evaluation program was notoriously slow – glacial would be a word one could use…  Bottom line, the process just wasn’t responsive enough to keep up with the changes and improvements in technology.  Products would be in evaluation for years before coming out of the process with their enabling technology nearly obsolete.   It didn’t matter, it was the only game in town until NIST and the Common Criteria labs  came onto the scene.  This has worked well, however the reality is, it’s not much better at vetting and moving technology from vendors to users.  The problem is, the evaluation process takes time and time means money, but it also means that the code submitted for evaluation will most likely be several revisions old by the time it emerges from evaluation.   Granted, it may only be 6 months, but it might take a year – regardless, this is far better than before.

So…  practically speaking, if the base version of FooOS submitted for evaluation is, say Version 5.0.1, several revisions —  each solving operational problems affecting the  organization — may have been released.  We may find that we need to run Version 5.6.10r3 in order to pass encrypted traffic via the network.  Because we encrypt traffic we must use FIPS-Level 2 certified code – but in the example above, the validated version of the FooOS will not work in our network…    What does the CISO do?  We’ll return to this in a moment, it gets better!

In order to reach levels of FIPS-140 goodness, one vendor in particular has instituted “FIPS Mode.”  What this does is require administration of the box from apposition directly in front  of the equipment, or at the length of your longest console cable…  Clearly, this is not suitable for organizations with equipment deployed worldwide to locations that do not have qualified administrators or network engineers.  Further, having to fly a technician to Burundi to clear sessions on a box every time it becomes catatonic is ridiculous at worst.  At best it’s not in accordance with the network concept of operations.  How does the CISO propose a workable, secure solution?

Standard Hill photo by timparkinson.

Now to my point.  (about time Vlad)   How does the CISO approach this situation?  Allow me to tell you the approach I’ve taken….

1. Accept the fact that once Foo OS has achieved a level of FIPS-140 goodness, the likelihood that the modules of code within the OS implementing cryptographic functionality in follow-on versions have not been changed.  This also means you have to assume the vendor has done a good job of documenting the changes to their baseline in their release notes, and that they HAVE modular code…

2. Delve into vendor documentation and FIPS-140 to find out exactly what “FIPS Mode” is, its benefits and the requirement.  Much of the written documentation in the standard deals with physical security of the cryptographic module itself (e.g., tamper-evident seals) – but most helpful is Table 1.

Bottom line — some “features” are indeed useful,  but this one particular vendor’s implementation into a “one-size fits all” option tends to limit the use of the feature at all in some operational scenarios (most notably, the one your humble author is dealing with.)  BTW, changing vendors is not an option.

3. Upon analyzing the FIPS requirements against operational needs, and (importantly) the environment the equipment is operating in, one has to draw the line between “operating in vendor FIPS Mode,” and using FIPS 140-2 encryption.

4. Document the decision and the rationale.

Once again, security professionals have to help managers to strike a healthy balance between “enough” security and operational requirements.   You would think that using approved equipment, operating systems, and vendors using the CC evaluation process would be enough.  Reading the standard, we see the official acknowledgement that “Your Mileage May Indeed Vary:” ^TM

“While the security requirements specified in this standard are intended to maintain the security provided by a cryptographic module, conformance to this standard is not sufficient to ensure that a particular module is secure. The operator of a cryptographic module is responsible for ensuring that the security provided by a module is sufficient and acceptable to the owner of the information that is being protected and that any residual risk is acknowledged and accepted.”     FIPS 140-2 Sec 15, Qualifications

The next paragraph constitutes validation of the approach I’ve embraced:

“Similarly, the use of a validated cryptographic module in a computer or telecommunications system does not guarantee the security of the overall system. The responsible authority in each agency shall ensure that the security of the system is sufficient and acceptable.”  (Emphasis added.)

One could say, “it depends,” but you wouldn’t think so at first glance – it’s a Standard for Pete’s sake!

Then again, nobody said this job would be easy!

Vlad

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Ever feel lost and lonely when staring at the business end of an ST&E?  Confounded and confused considering Configuration controls?  Perplexed and Puzzled at Planning procedures?  Anxious or amazed at Audit and Accountability assessments?  Annoyed at aimless alliteration?

NIST has heard your muttered curses and answered them!  (Except the annoying alliteration, which is my fault.)

Now available are the Assessment Cases for Special Publication 800-53A.  The Assessment Cases offer supplemental guidance on assessing security controls found in the recently released SP 800-53A Guide for Assessing the Security Controls in Federal Information Systems (PDF Warning).  These documents are in their Initial Public Draft so be sure to give them a look and provide some feedback.

The Assessment Cases contain consensus recommendations from the Assessment Cases Project on specific actions to perform when assessing security controls.  These specific actions are intended to complement the assessment procedures documented in NIST SP 800-53A.   Yes, you heard that right, Specific Actions.  Less time spent pondering how to “Examine: … other relevant documents or records”.

The Assessment Cases Project is an inter-agency workgroup headed by DoJ with members including NIST, DoE, DoT and ODNI-CIO.  Many thanks for the hard work of this workgroup’s membership.  You may not be able to hear it but I am applauding on this side of the keyboard.  And a big thanks to Patrick O’Reilly for pointing me to this wonderful resource.

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Guys, please remember that the controls from SP 800-53 and the test cases from SP 800-53A need to be tailored.  Otherwise, they’re as useful as a watermelon in a lake is to a kitteh.

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