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.

Bookmark to:

Hide Sites

A small presentation Dan Philpott and I put together for Potomac Forum about getting sane social media policy out of your security staff. I also recommend reading something I put out a couple of months ago about Social Media Threats and Web 2.0.

Bookmark to:

Hide Sites

For those of you who didn’t know the real purpose of DojoCon, it was to raise money and awareness for Hackers for Charity. If you like anything that is in this post, go to HFC and make a donation of time, equipment, tech support, and maybe money. If you’ve never heard of HFC because you’re not one of the “InfoSec Cool Kids”, now is your chance–go read about them.

The video of my dojocon presentation. The microphone was off for the first couple of minutes but I look pretty animated.

And then the compliance panel that I tried not to dominate:

And finally, my slides are up on slideshare:

Bookmark to:

Hide Sites

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.

Bookmark to:

Hide Sites

Letter from GAO on how Congress can fix FISMA.  And oh yeah, the press coverage on it.

Now supposedly this was in response to an inquiry from Congress about “Please comment on the need for improved cyber security relating to S.773, the proposed Cybersecurity Act of 2009.”  This is S.773.

GAO is mixing issues and has missed the mark on what Congress asked for.  S.773 is all about protecting critical infrastructure.  It only rarely mentions government internal IT issues.  S.773 has nothing at all to do with FISMA reform.  However, GAO doesn’t have much expertise in cybersecurity outside of the Federal Agencies (they have some, but I would never call it extensive), so they reported on what they know.

The GAO report used the often-cited metric of an increase in cybersecurity attacks against Government IT systems growing from “5,503 incidents reported in fiscal year 2006 to 16,843 incidents in fiscal year 2008″ as proof that the agencies are not doing anything to fix the problem.  I’ve questioned these figures before, it’s associated with the measurement problem and increased reporting requirements more than an increase in attacks.  Truth be told, nobody knows if the attacks are increasing and, if so, at what rate.  I would guess they’re increasing, but we don’t know, so quit citing some “whacked” metric as proof.

Reform photo by shevy.

GAO’s recommendations for FISMA Reform:

Clarify requirements for testing and evaluating security controls.  In other words, the auditing shall continue until the scores improve.  Hate to tell you this, but really all you can test at the national level is if the FISMA framework is in place, the execution of the framework (and by extension, if an agency is secure or not) is largely untestable using any kind of a framework.

Require agency heads to provide an assurance statement on the overall adequacy and effectiveness of the agency’s information security program.  This is harkening back to the accounting roots of GAO.  Basically what we’re talking here is for the agency head to attest that his agency has made the best effort that it can to protect their IT.  I like part of this because part of what’s missing is ”executive support” for IT security.  To be honest, though, most agency heads aren’t IT security dweebs, they would be signing an assurance statement based upon what their CIO/CISO put in the executive summary.

Enhance independent annual evaluations.  This has significant cost implications.  Besides, we’re getting more and more evaluations as time goes on with an increase in audit burden.  IE, in the Government IT security space, how much of your time is spent providing proof to auditors versus building security?  For some people, it’s their full-time job.

Strengthen annual reporting mechanisms.  More reporting.  I don’t think it needs to get strengthened, I think it needs to get “fixed”.  And by “fixed” I mean real metrics.  I’ve touched on this at least a hundred times, go check out some of it….

Strengthen OMB oversight of agency information security programs.  This one gives me brain-hurt.  OMB has exactly the amount of oversight that they need to do their job.  Just like more auditing, if you increase the oversight and the people doing the execution have the same amount of people and the same amount of funding and the same types of skills, do you really expect them to perform differently?

Rybolov’s synopsis:

When the only tool you have is a hammer, every problem looks like a nail, and I think that’s what GAO is doing here.  Since performance in IT security is obviously down, they suggest that more auditing and oversight will help.  But then again, at what point does the audit burden tip to the point where nobody is really doing any work at all except for answering to audit requests?

Going back to what Congress really asked for, We run up against a problem.  There isn’t a huge set of information about how the rest of the nation is doing with cybersecurity.  There’s the Verizon DBIR, the Data Loss DB, some surveys, and that’s about it.

So really, when you ask GAO to find out what the national cybersecurity situation is, all you’re going to get is a bunch of information about how government IT systems line up and maybe some anecdotes about critical infrastructure.

Coming to a blog near you (hopefully soon): Rybolov’s 5 steps to “fix” FISMA.

Bookmark to:

Hide Sites

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.

Bookmark to:

Hide Sites