FedRAMP: It’s Here but Not Yet Here

Posted December 12th, 2011 by

Contrary to what you might hear this week in the trade press, FedRAMP is not fully unveiled although there was some much-awaited progress. There was a memo that came out from the administration (PDF caveat).  Basically what it does is lay down the authority and responsibility for the Program Management Office and set some timelines.  This is good, and we needed it a year and a half ago.

However, people need to stop talking about how FedRAMP has solved all their problems because the entire program isn’t here yet.  Until you have a process document and a catalog of controls to evaluate, you don’t know how the program is going to help or hinder you, so all the press about it is speculation.



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FedRAMP is Officially Out

Posted November 3rd, 2010 by

Go check it out.  The project management folks have been jokingly grilled over numerous times for being ~2-3 months late.

However, comments are being accepted until December 2nd.  Do yourselves a favor and submit some comments.



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Split-Horizon Assessments and the Oversight Effect

Posted July 7th, 2010 by

Going Off the Deep End

So I was thinking the other day (this is the part where people who know me in person usually go “oh cr*p”), partially spurred by a conversation I had with @csoandy and @secbarbie a couple of months ago.  I’ll get the idea out there: as an industry we need to embrace the concept of split-horizon assessments.

Two Purposes for Assessments

Because this is an insane approach that I’m just feeling out, let me go on a solo riff and explain what I’m talking about.  You see, I have two distinct purposes for getting a security assessment, both of which are in contention with each other:

  • I want to fix my security by asking for money to fix the things that need attention.  When I get an assessment for this purpose, enumeration of my badness/suckness is good.  If I have a set of results that say that everything is great, then there’s no need for me to be given any more resources (time, money, people, gear).  Short-term, I’m fine, but what about my infrastructure-type long-term projects?  The net effect of a highly-scored annual assessment just might kill my program in 2 years as my funding and people are shifted elsewhere, especially in a .
  • I want to keep my job and help my {company|agency|group} stay out of trouble by showing my zero-defects face and by demonstrating my due-diligence in protecting what has been given to me.  While the assessor has helped me short-term by identifying my problems and being a total hardass, if I’m not around in 6 months to adopt the recommendations into my security program, has the assessor actually helped me?

And this is the dilemma for just about every security manager out there.  One of the strategies is to alternate assessment types, but then your management wonder just what the heck it is you’re doing because you’re on top one year, then on the bottom the next.

Split Rock Lighthouse and Horizon photo by puliarf.

Assessor Window-Shopping

Now for the dirty little secret of the testing business:  there are really good testers who are the ninjas of the InfoSec world and there are really bad testers who don’t even validate their unlicensed Nessus scan.  I know, you’re shocked and it’s so blindingly obvious that Bruce Schneier will blog it 3 years from now.  =)

But there’s the part that you didn’t know:  security managers pick their assessor depending on the political mood inside their organization.  This is nowhere near a science, from what I’ve seen it involves a lot of navel-gazing on the part of the security team to see which is the lesser evil: having everybody think you’re incompetent or never getting anything new ever again?

Building a Better Rat Race

In order to accomplish both of the goals that I’ve listed, what I really need is a split-horizon assessment.  In other words, I need 2 reports from one assessment with different views for different audiences.  I know this sounds highly cynical, but it’s something we’ve been doing for some time now but just informally.  Might as well make it formal.

So are you sold on this concept yet?  In true form, I have an idea on how to get to a world of split-horizon assessments.  You can take any catalog of controls and divide it into “gotta have it” and “nice to have” (I almost divide these along the lines of “vulnerability mitigation” and “sustainable security program” or the “CISO” and “OMB and Congress”) buckets.  Then in your compliance assessment standard, require 2 reports for each assessment.  One is reported to the regulating authority and the other stays with the organization.

Indecision Strikes

I don’t know if I’ve solved the problemspace or not, but I’m looking for feedback “from the Peanut Gallery” so leave some comments.



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How to Not Let FISMA Become a Paperwork Exercise

Posted June 7th, 2010 by

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.



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“Machines Don’t Cause Risk, People Do!”

Posted May 26th, 2010 by

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

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.”



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The Guerilla CISO Rants: Don’t Write a System Security Plan

Posted October 1st, 2009 by

OK, I know you’re shocked…I’m saying something controversial.  But hear me out on this one, I’ll explain.

Now this is my major beef with the way we write SSPs today:  this is all information that is contained in other artifacts that I have to pay people to do cut-and-paste to get it into a SSP template.  As practiced, we seriously have a problem with polyinstantiation of data in various lifecycle artifacts that is cut-and-pasted into an SSP.  Every time you change the upstream document, you create a difference between that document and the SSP.

This is a practice I would like to change, but I can’t do it all by myself.

This is the skeleton outline of an SSP from Special Publication 800-18, the guide to writing an SSP:

  1. Information System Name/Title–On the investment/FISMA inventory, the Exhibit 300/53, etc
  2. Information System Categorization–usually on a FIPS-199 memorandum
  3. Information System Owner–In an assignment memo
  4. Authorizing Official–In an assignment memo
  5. Other Designated Contacts–In an assignment memo
  6. Assignment of Security Responsibility–In assignment memos
  7. Information System Operational Status–On the investment/FISMA inventory, the Exhibit 300/53, etc
  8. Information System Type–On the investment/FISMA inventory, the Exhibit 300/53, etc
  9. General System Description/Purpose–In the design document, Exhibit 300/53
  10. System Environment–Common controls not inside the scope of our system
  11. System Interconnections/Information Sharing–from Interconnection Security Agreements
  12. Related Laws/Regulations/Policies–Should be part of the system categorization but hardly ever is on templates
  13. Minimum Security Controls–800-53 controls descriptions which can easily be done in a Requirements Traceability Matrix
  14. Information System Security Plan Completion Date–specific to each document
  15. Information System Security Plan Approval Date–specific to each document

Now some of this has changed in practice a little bit–# 10 can functionally be replaced with a designation of common controls and hybrid controls.

So my line of thinking is that if we provide a 2-6-page system description with the names of the “guilty parties” and some inventory information, controls-specific Requirements Traceability Matrix, and a System Design Document, then we have the functional equivalent of an SSP.

Why have I declared an InfoSec fatwah against SSPs as currently practiced?

Well, my philosophy for operation is based on some concepts I’ve picked up through the years:

  • Why run when you can walk, why walk when you can sit, why sit when you can lay down.  There is a time to spend effort on determining what the security controls are for a project.  You need to have them documented but it’s not cost-effective to be worried about format, which we do probably too much of today.
  • Make it easy to do the right thing.  If we polyinstantiate security information, we have made something harder to maintain.  Easier to maintain means that it will get maintained instead of being shelfware.  I would rather have updated and accurate security information than overly verbose and well-polished documents that are inaccurate.
  • Security is not a “security guy thing”–most problems are actually a management and project team problem.  My idea uses their SDLC artifacts instead of security-specific versions of artifacts.  My idea puts the project problems back in the project space where it belongs.
  • If I have a security engineer who has a finite amount of hours in a day, I have to choose what they spend their time on.  If it’s a matter of vulnerability mitigation, patching, etc, or correcting SSP grammar, I know what I want him to do.  Then again, I’m still an infantryman deep down inside and I realize I have biases against flowery writing.

Criticisms to not writing a dedicated SSP document:

“My auditors are used to seeing the information in the same format at someplace they worked previously”. Believe it or not, I hear this quite a bit.  My response is along the lines of the fact that if you make your standard be what I’m suggesting for a security plan, then you’ve met all of the FISMA and 800-53 requirements and my personal requirement to “don’t do stupid stuff if you can help it”.

“My auditors will grill me to death if they have to page back and forth between several documents”.  This one also I’ve heard.  There are a couple of ways to deal with this.  One way to deal with this is that in your 800-53 Requirements Traceability Matrix you reference the source document.  Most auditors at this point bring up that you need to reference the official name, date of publication, and specific page/section of the reference and I think they need to get a life because they’ve taken us back to the maintainability problem.

“This is all too new-school and I can’t get over it”. Then you are a dinosaur and your kind deserves extinction.  =)

.

This blog post is for grecs at novainfosecportal.com who perked up instantly when I mentioned the concept months ago.  Finally got around to putting the text somewhere.

How to Plan the Perfect Dinner Party photo by kevindooley.



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