Ever watch a marathon on TV? There’s the usual formula for how we lay out the day:
- History of the marathon and Pheidippides
- Discussion of the race length and how it was changes so that the Queen could watch the finish
- World records and what our chances are for making one today
- Graphics of the race course showing the key hills and the “sprint to the finish”
- Talk about the womens’ marathon including Joan Benoit and Kathrine Switzer
- Description of energy depletion and “The Wall”
- Stats as the leaders hit the finsh line
- Shots of “back-of-the-pack” runners and the race against yourself
Well, I now present to you the formula for FISMA Report Cards:
- Paragraph about how agencies are failing to secure their data, the report card says so
- History and trending of the report card
- Discussion on changing FISMA
- Quote from Karen Evans
- Quote from Alan Paller about how FISMA is a failure and checklist-driven security
- Wondering when the government will get their act together
Have a read of Dancho’s response to the FISMA Report Card. Pretty typical writing formula that you’ll see from journalists. I won’t even comment on the “FISMA compliance” title. Oh wait, I just did. =)
Some myths about FISMA in particular that I need to dispell right now:
- FISMA is a report card: It’s a law, the grades are just an awareness campaign. In fact, the whole series of NIST Special Publications are just implementation techniques–they are guidance after all. Usually the media and bloggers talk about what FISMA measures and um, well, it doesn’t measure anything, it just requires that agencies have security programs based on a short list of criteria such as security planning, contingency planning, and security testing. It just goes back to the adage that nobody really knows what FISMA is.
- FISMA needs to be changed: As a law, FISMA is exactly where it needs to be. Yes, Congress does have talks about modifying FISMA, but not much has come of it because what they eventually discover after much debate and sword-waving is that FISMA is the way to write the law about security, the problem is with the execution at all levels–OMB, GAO, and the agencies–and typically across organizational boundaries and competing master agendas.
- There is a viable alternative framework: Dancho points out this framework in his post which is really an auditors’ plugin to the existing NIST Framework for FISMA. Thing is, nobody has a viable alternative framework because it’s still going to be the same people with the same training executing in the same environment.
Way back last year I wrote a blog post about indicator species and how we’re expecting the metrics to go up based on our continual measuring of them. Every couple of months I go back and review it to see if it’s still relevant. And the answer this week is “yes”.
Now I’ve been thinking and talking probably too much about FISMA and the grades over the past couple of years, so occassionally I come to conclusions . According to Mr Vlad the Impaler, the report card is a bad idea, but I’m slowly beginning to see the wisdom of it: it’s an opportunity to have a debate and to raise some awareness of Government security outside of those of us who do it. The only other time that we have a public debate about security is after a serious data breach, and that’s not a happy time.
I just wish the media would stop with the story line that FISMA is failing because the grades provide recursive evidence of it.
Posted in FISMA, NIST, What Doesn't Work, What Works | 9 Comments »
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