Why We Need PCI-DSS to Survive

Posted June 9th, 2009 by

And by “We”, I mean the security industry as a whole.  And yes, this is your public-policy lesson for today, let me drag my soapbox over here and sit for a spell while I talk at you.

By “Survive”, I mean that we need some kind of self-regulatory framework that fulfills the niche that PCI-DSS occupies currently. Keep reading, I’ll explain.

And the “Why” is a magical phrase, everybody say it after me: self-regulatory organization.  In other words, the IT industry (and the Payment Card Industry) needs to regulate itself before it crosses the line into being considered for statutory regulation (ie, making a law) by the Federal Government.

Remember the PCI-DSS hearings with the House Committe on Homeland Security (AKA the Thompson Committee)?  All the Security Twits were abuzz about it, and it did my heart great justice to hear all the cool kids become security and public policy wonks at least for an afternoon.  Well, there is a little secret here and that is that when Congress gets involved, they’re gathering information to determine if they need to regulate an industry.  That’s about all Congress can do: make laws that you (and the Executive Branch) have to follow, maybe divvy up some tax money, and bring people in to testify.  Other than that, it’s just positioning to gain favor with other politicians and maybe some votes in the next election.

Regulation means audits and more compliance.  They go together like TCP and IP.  Most regulatory laws have at least some designation for a party who will perform oversight.  They have to do this because, well, if you’re not audited/assessed/evaluated/whatever, then it’s really an optional law, which doesn’t make sense at all.

Yay Audits photo by joebeone.

Another magical phrase that the public policy sector can share with the information security world: audit burden.  Audit burden is how much a company or individual pays both in direct costs (paying the auditors) and in indirect costs (babysitting the auditors, producing evidence for the auditors, taking people away from making money to talk to auditors, “audit requirements”, etc).  I think we can all agree that low audit burden is good, high audit burden is bad.  In fact, I think that’s one of the problems with FISMA as implemented is that it has a high audit burden with moderately tangible results. But I digress, this post is about PCI-DSS.

There’s even a concept that is mulling around in the back of my head to make a metric that compares the audit burden to the amount of security that it provides to the amount of assurance that it provides against statutory regulation.  It almost sounds like the start of a balanced scorecard for security management frameworks, now if I could get @alexhutton to jump on it, his quant brain would churn out great things in short order.

But this is the lesson for today: self-regulation is preferrable to legislation.

  • Self-regulation is defined by people in the industry.  Think about the State Bar Association setting the standards for who is allowed to practice law.
  • Standards ideally become codified versions of “best practices”.  OK, this is if they’re done correctly, more to follow.
  • Standards are more flexible than laws.  As hard/cumbersome as it is to change a standard, the time involved in changing a law is prohibitive most of the time unless you’re running for reelection.
  • Standards sometimes can be “tainted” to force out competition, laws are even more so.

The sad fact here is that if we don’t figure out as an industry how to make PCI-DSS or any other forms of self-regulation work, Congress will regulate for us.  Don’t like PCI-DSS because of the audit burden, wait until you have a law that requires you to do the same controls framework.  It will be the same thing, only with bigger penalties for failure, larger audit burdens to avoid the larger penalties, larger industries created to satisfy the market demand for audit.  Come meet the new regulatory body, same as the old only bigger and meaner. =)

However, self-regulation works if you do it right, and by right I mean this:

  • The process is transparent and not the product of a secret back-room cabbal.
  • Representation from all the shareholders.  For PCI-DSS, that would be Visa/MasterCard, banks, processors, large merchants, small merchants, and some of the actual customers.
  • The standards committee knows how to compromise and come to a consensus.  IE, we can’t have both full hard drive encryption, a WAF, code review, and sacrificing of chickens in the server room, so we’ll make one of the 4 mandatory.
  • The regulatory organization has a grievance process for its constituency to present valid (AKA “Not just more whining”) discrepencies in the standards and processes for clarification or consideration for change.
  • The standard is “owned” by every member of the constituency.  Right now, people governed by PCI-DSS are not feeling that the standard is their standard and that they have a say in what comprises the standard and that they are the ones being helped by the standard.  Some of that is true, some of that is an image problem.  The way you combat this is by doing the things that I mentioned in the previous bullets.

Hmm, sounds like making an ISO standard, which brings its own set of politics.

While we need some form of self-regulation, right now PCI-DSS and ISO 27001 are the closest that we have in the private sector.  Yeah, it sucks, but it sucks the least, just like our form of government.

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Posted in Public Policy, Rants | 11 Comments »

Some Thoughts on POA&M Abuse

Posted June 8th, 2009 by

Ack, Plans of Action and Milestones.  I love them and I hate them.

For those of you who “don’t habla Federali”, a POA&M is basically an IOU from the system owner to the accreditor that yes, we will fix something but for some reason we can’t do it right now.  Usually these are findings from Security Test and Evaluation (ST&E) or Certification and Accreditation (C&A).  In fact, some places I’ve worked, they won’t make new POA&Ms unless they’re traceable back to ST&E results.

Functions that a POA&M fulfills:

  • Issue tracking to resolution
  • Serves as a “risk register”
  • Used as the justification for budget
  • Generate mitigation metrics
  • Can be used for data-mining to find common vulnerabilities across systems

But today, we’re going to talk about POA&M abuse.  I’ve seen my fair share of this.

Conflicting Goals: The basic problem is that we want POA&Ms to satisfy too many conflicting functions.  IE, if we use the number of open POA&Ms as a metric to determine if our system owners are doing their job and closing out issues but we also turn around and report these at an enterprise level to OMB or at the department level, then it’s a conflict of interest to get these closed as fast as possible, even if it means losing your ability to track things at the system level or to spend the time doing things that solve long-term security problems–our vulnerability/weakness/risk management process forces us into creating small, easily-to-satisfy POA&Ms instead of long-term projects.

Near-Term v/s Long-Term:  If we set up POA&Ms with due dates of 30-60-90 (for high, moderate, and low risks) days, we don’t really have time at all to turn these POA&Ms into budget support.  Well, if we manage the budget up to 3 years in advance and we have 90 days for high-risk findings, then that means we’ll have exactly 0 input into the budget from any POA&M unless we can delay the bugger for 2 years or so, much too long for it to actually be fixable.

Bad POA&Ms:  Let’s face it, sometimes the one-for-one nature of ST&E, C&A, and risk assessment findings to POA&Ms means that you get POA&Ms that are “bad” and by that I mean that they can’t be satisfied or they’re not really something that you need to fix.

Some of the bad POA&Ms I’ve seen, these are paraphrased from the original:

  • The solution uses {Microsoft|Sun|Oracle} products which has a history of vulnerabilities.
  • The project team needs to tell the vendor to put IPV6 into their product roadmap
  • The project team needs to implement X which is a common control provided at the enterprise level
  • The System Owner and DAA have accepted this risk but we’re still turning it into a POA&M
  • This is a common control that we really should handle at the enterprise level but we’re putting it on your POA&M list for a simple web application

Plan of Action for Refresh Philly photo by jonny goldstein.

Keys to POA&M Nirvana:  So over the years, I’ve observed some techniques for success in working with POA&Ms:

  • Agree on the evidence/proof of POA&M closure when the POA&M is created
  • Fix it before it becomes a POA&M
  • Have a waiver or exception process that requires a cost-benefit-risk analysis
  • Start with”high-level” POA&Ms and work down to more detailed POA&Ms as your security program matures
  • POA&Ms are between the System Owner and the DAA, but the System Owner can turn around and negotiate a POA&M as a cedural with an outsourced IT provider

And then the keys to Building Good POA&Ms:

  • Actionable–ie, they have something that you need to do
  • Achievable–they can be accomplished
  • Demonstrable–you can demonstrate that the POA&M has been satisfied
  • Properly-Scoped–absorbed at the agency level, the common control level, or the system level
  • They are SMART: Specific, Manageable, Attainable, Relevant, and within a specified Timeframe
  • They are DUMB: Doable, Understandable, Manageable, and Beneficial

Yes, I stole the last 2 bullets from the picture above, but they make really good sense in a way that “know thyself” is awesome advice from the Oracle at Delphi.

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Posted in BSOFH, FISMA | No Comments »

Working with Interpreters, a Risk Manager’s Guide

Posted June 3rd, 2009 by

So how does the Guerilla-CISO staff communicate with the locals on jaunts to foreign lands such as Deleware, New Jersey, and Afghanistan?  The answer is simple, we use interpreters, known in infantrese as “terps”.  Yes, you might not trust them deep down inside because they harbor all kinds of loyalties so complex that you can spend the rest of your life figuring out, but you can’t do the job without them.

But in remembering how we used our interpreters, I’m reminded of some basic concepts that might be transferable to the IT security and risk management world.  Or maybe not, at least kick back and enjoy the storytelling while it’s free. =)

Know When to Treat Them Like Mushrooms: And by that, we mean “keep them in the dark and feed them bullsh*t”.  What really mean is to tell potentially adversarial people that you’re working with the least amount of information that they need to do their job in order to limit the frequency and impact of them doing something nasty.  When you’re planning a patrol, the worst way to ruin your week is to tell the terps when you’re leaving and where you’re going.  That way, they can call their Taliban friends when you’re not looking and they’ll have a surprise waiting for you.  No, it won’t be a birthday cake.  The way I would get a terp is that one would be assigned to me by our battalion staff and the night before the patrol I would tell the specific terp that we were leaving in the morning, give them a time that I would come by to check up on them, and that they would need to bring enough gear for 5 days.  Before they got into my vehicles and we rolled away, I would look through their gear to make sure they didn’t have any kind of communications device (radio or telephone) to let their buddies know where we were at.

Fudge the Schedule to Minimize Project Risk: Terps–even the good ones–are notorious for being on “local time”, which for a patrol means one hour later than you told them you were leaving.  The good part about this is that it’s way better than true local time, which has a margin of error of a week and a half.  In order to keep from being late, always tell the terps when you’ll need them an hour and a half before you really do, then check up on them every half hour or so.  Out on patrol, I would cut that margin down to half an hour because they didn’t have all the typical distractions to make them late.

Talk Slowly, Avoid Complex Sentences: The first skill to learn when using terps is to say things that their understanding of English can handle.  When they’re doing their job for you, simple sentences works best.  I know I’m walking down the road of heresy, but this is where quantitative risk assessment done poorly doesn’t work for me because now I something that’s entirely too complex to interpret to the non-IT crowd.  In fact, it probably is worse than no risk assessment at all because it comes accross as “consultantspeak” with no tangible link back to reality.

Put Your Resources Where the Greatest Risk Is: To a vehicle patrol out in the desert, most of the action happens at the front of the patrol.  That’s where you need a terp.  That way, the small stuff, such as asking a local farmer to move his goats and sheep out of the road so you can drive through, stays small–without a terp up front, a 2-minute conversation becomes 15 minutes of hassle as you first have to get the terp up to the front of the patrol then tell them what’s going on.

Pigs, Chicken, and Roadside Bombs: We all know the story about how in the eggs and bacon breakfast, the chicken is a participant but the pig is committed.  Well, when I go on a patrol with a terp, I want them to be committed.  That means riding in the front vehicle with me.  It’s my “poison pill” defense in knowing that if my terp tipped off the Taliban and they blow up the lead vehicle with me in it, at least they would also get the terp.  A little bit of risk-sharing in a venture goes a long way at getting honesty out of people.

Share Risk in a Culturally-Acceptable Way: Our terps would balk at the idea of riding in the front vehicle most of the time.  I don’t blame them, it’s the vehicle most likely to be turned into 2 tons of slag metal thanks to pressure plates hooked up to IEDs.  The typical American response is something along the lines of “It’s your country, you’re riding up front with me so if I get blown up, you do to”.  Yes, I share that ideal, but the Afghanis don’t understand country loyalties, the only thing they understand is their tribe, their village, and their family.  The Guerilla-CISO method here is to get down inside their heads by saying “Come ride with me, if we die, we die together like brothers”.  You’re saying the same thing basically but you’re framing it in a cultural context that they can’t say no to.

Reward People Willing to Embrace Your Risks: One of the ways that I was effective in dealing with the terps was that I would check in occassionally to see if they were doing alright during down-time from missions.  They would show me some Bollywood movies dubbed into Pashto, I would give them fatty American foods (Little Debbie FTW!).  They would play their music.  I would make fun of their music and amaze them because they never figured out how I knew that the song had drums, a stringed instrument, and somebody singing (hey, all their favorite songs have that).  They would share their “foot bread” (the bread is stamped flat by people walking on it before it’s cooked, I was too scared to ask if they washed their feet first) with me.  I would teach them how to say “Barbara (their assignment scheduler back on an airbase) was a <censored> for putting them out in the middle of nowhere on this assignment” and other savory phrases.  These forays weren’t for my own enjoyment, but to build rapport with the terps so that they would understand when I would give them some risk management love, Guerilla-CISO style.

Police, Afghan Army and an Interpreter photo by ME!.  The guy in the baseball cap and glasses is one of the best terps I ever worked with.

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Posted in Army, Risk Management, The Guerilla CISO, What Works | 1 Comment »

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