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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Posted in FISMA, NIST, Rants, Risk Management, What Doesn't Work, What Works | 2 Comments »

“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

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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Posted in FISMA, NIST, Public Policy, Rants, Risk Management, What Doesn't Work, What Works | 14 Comments »

A Little Advice From Mike and Lee

Posted April 20th, 2010 by

Go have a look at what Mike Murray and Lee Kushner have to say on what I endearingly refer to as “Stupid Contractor Tricks”.

Now I know Mike and Lee are supposed to be tactful, and they do a really good job at that.  This post is not about tact.  =)

You need to step back a bit and understand the business model for contractors.  Because their margins are low and fixed, it means a couple of things:

  • You have large-volume contracts where you still have the same margin but more total net profit.
  • You can’t keep a bench of people off-project because it rapidly eats into your margin.  For some companies, this means that anybody off-project for 2 weeks or more gets laid off.
  • The name of the game is to win the proposal, get the work, then figure out how to staff it from rolling people onto the new project and bringing in new hires.  This is vastly inefficient.
  • New hires can also be to backfill on contracts where you’ve moved key people off to work something new.

So on to my advice in this particular scenario that Mike and Lee discuss:  Run away as fast as you can from this offer.

There are a couple of other things that I’m thinking about here:

  • A recruiter or HR person from Company A left for Company B and took their Rolodex of candidates.  Hence the surprise offer.  Either that, or Company A is now a sub for Company B or Company A is just the “staffing firm” getting paid $500/signed offer letter and doing business in bulk.
  • The Government usually requires “Commitment Letters” from the people that have resumes submitted on a proposal.  The reason for this is that the Government realizes what kind of jackassery goes on involving staffing, and requiring a signed letter gives the candidate an opportunity to decide up front.
  • If you sign an offer like this, you’re letting down the rest of the InfoSec community that are contractors by letting the recruiters commoditize what we do.  It’s bad for us and it’s bad for the Government.

Other stupid contractor tricks:

  • Signing an exclusivity letter that they are the only people who can submit your resume on a contract.
  • Making you sign an offer letter then letting the offer linger for 6+ months while you’re unemployed and could really use the ability to move on to a different job.
  • Shopping resumes for people you have never met and/or do not intend to make an offer letter to.
  • Changing the job completely after you have accepted the offer.
  • …and you probably have more that you can put into the comments section below.  =)

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Posted in Odds-n-Sods, Rants, What Doesn't Work | 2 Comments »

I’m on the OWASP Podcast

Posted October 1st, 2009 by

I sat down with Jim Manico a month or so ago when he was in DC and recorded a podcast for the OWASP Podcast.  It’s now live, check it out.

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Posted in FISMA, NIST, Public Policy, Rants, Speaking, The Guerilla CISO | No Comments »

The CyberArmy You Have…

Posted July 27th, 2009 by

In the military, there is a saying: “You go to war with the army you have, not with the army you wish you had.”  In other words, you do all your training in peace and once you go off to war, it’s too late to fix it. Not that I agree with all the Cyber Pearl Harbor doomsayers, but I think that the CyberArmy we got now isn’t the right one for the job.

So, let’s talk about services firms, contractors fit into this nicely since, well, they perform services.

There are 4 types of work that services firms do (and contractors are services firms):

  • Brains: nobody else has done this before, but we hire a whole bunch of PhD people who can research how to get this done.  We charge really high prices but it’s because in the downtime, our people are doing presentations, going to symposiums, and working on things that you don’t even know exist.  Think old-school L0pht.  Think half of Mitre.  Think sharks with friggin laser beams, lasing and eating everything in sight.
  • Gray Hair: We’ve done this before and know most of the problems that we can experience, along with the battle scars to prove it.  We charge quite a bit because we’re good and it takes less of us to get it done than our competitors.  Think most good IT engineers.  Think DLP and DAM right now.  Think infantry platoon sergeants.
  • Procedural: There is a fairly sizeable market starting to grow around this service so we have to standardize quite a bit to reduce our costs to provide the service.  We use methodologies and tools so that we can take an army of trained college graduates, put them in a project, and they can execute according to plan.  Think audit staff.  Think help desk staff.  Think of an efficient DMV.
  • Commodity: There isn’t a differentiator between competitors, so companies compete on price.  The way you make money is by making your cost of production lower or selling in volume.  Think Anti-Virus software (sorry friends, it’s true).  Think security guards.  Think peanut butter.

This is also the maturity model for technology, so you can take any kind of tech, drop it in at the top, and it percolates down to the bottom.  Think Internet use: First it was the academics, then the contractors, then the technology early adopters on CompuServe, then free Internet access to all.  For most technology, it’s a 5-10 year cycle to get from the top to the bottom.  You already know this: the skills you have now will be obsolete in 5 years.

Procedural Permit Required photo by Dawn Endico.

Now looking at government contracting….

As a government contractor, you are audited financially by DCAA and they add up all your costs and let you keep a fixed margin of around 13-20%.  You can pull some Stupid Contractor Tricks ™ like paying salaries and working your people 60 hours/week (this is called uncompensated overtime), but there still is a limit to what you can do.

This fixed margin forces you into high-volume work to turn a profit.  This in turn forces you into procedural or even commodity work.

If your project is strictly time and material, you make more money off the cheaper folks but for quality of work reasons, you have to provide them with a playbook of some sort.  This pushes you directly into the procedural tier.

There are some contractors providing services at the Brains and Gray Hair stages, only they are few and far between.

Traditional types of contractor security services:

  • Security Program Management and Governance
  • Audit and Penetration Testing
  • Compliance and Certification and Accreditation Support
  • Security Operations (think Managed Security Services)

Then back around to cyberwar…

Cyberwar right now is definitely at the top of the skill hierarchy.  We don’t have an official national strategy.  We have a Cybersecurity Coordinator that hasn’t been filled yet.  We need Brains people and their skills to figure this out.  In fact, we have a leadership drought.

And yet the existing contractor skillset is based on procedural offerings.  To be honest, I see lots of people with cybersecurity offerings, but what they really have is rebranded service offerings because the skills sets of the workforce haven’t changed.

Some of the procedural offerings work, but only if you keep them in limited scope.  The security operations folks have quite a few tranferable skills, so do the pen-testers.  However, these are all at the tactical level.  The managerial skills don’t transfer really at all unless you have people that are just well-rounded, usually with some kind of IT ops background.

But, and this is the important thing, we’re not ready to hire contractors until we do get some leadership in place. And that’s why the $25M question right now is “Who will that person be?”  Until that time, anything from the vendors and contractors is just posturing.

Once we get a national leadership and direction, then it’s a matter of lining up the services being offered with the needs at the time.  What I think we’ll find out at that time is that we’re grossly underrepresented in some areas and sadly underrepresented in some areas and that these areas are directly inverse to the skills that our current workforce has.  This part scares me.

We need workforce development.  There are some problems with this, mostly because it takes so long to “grow” somebody with the skills to get the job done–maybe 5-10 years with education and experience.  Sadly, about the time we build this workforce, the problem will have slid down the scale so that procedural offerings will probably work.  This frustrates me greatly.

The summary part…

Well, just like I don’t want to belong to any club that would stoop so low to have me as a member, it could be possible that almost all the contractors offering services aren’t the people that you want to hire for the job.

But then again, we need to figure out the leadership part first.  Sadly, that’s where we need the most love.  It’s been how many months with a significant leadership vacuum?  9? 12? 7 years?

The most critical step in building a cyberwar/cyberdefense/cyberfoo capability is in building a workforce.  We’re still stuck with the “option” of building the airplane while it’s taxiing down the runway.

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Posted in Cyberwar, Rants | 6 Comments »

Surprise Report: Not Enough Security Staff

Posted July 22nd, 2009 by

Somedays I feel like people are reading this blog and getting ideas that they turn around and steal.  Then I take my pills and my semi-narcisistic feelings go away.  =)

So anyway, B|A|H threw me for a loop this afternoon.  They released a report on the cybersecurity workforce.  You can check out the article on The Register or you can go get the report from here.  Surprise, we don’t have anywhere near enough security people to go around.  I’ve been saying this for years, I think B|A|H is stealing my ideas by using Van Eck phreaking on my brain while I sleep.

 Some revelations from the executive summary:

  • The pipeline of potential new talent is inadequate.  In other words, demand is growing and the amount of people that we’re training is not growing to meet the demand.
  • Fragmented governance and uncoordinated leadership hinders the ability to meet federal cybersecurity workforce needs.  Nobody’s so far been able to articulate how we build an adequate supply of security folks to keep up with demand and most of our efforts have been at the execution level.
  • Complicated processes and rules hamper recruiting and retention efforts.  It takes maybe 6 months to hire a government employee, this is entirely unsatisfactory.  My current project I was cleared for for 3 years, took a 9-month break, and it took me 6 months to get cleared again.
  • There is a disconnect between front-line hiring managers and government’s HR specialists.  Since the HR folks don’t know what the real job description is, hiring information security people is akin to buzzword bingo.

These are all the same problems the private sector deals with, only in true Government stylie, we have it on a larger scale.


He’s Part of the Workforce photo by pfig.

Now for the things that no self-respecting contractor will admit (hmm, what does this say about me?  I’m not sure yet)….

If you do not have an adequate supply of workers in the industry, outsourcing cybersecurity tasks to contractors will not work.  It works something like this:

  • High Demand = High Bill Rate.
  • High Bill Rate = More Contractor Interest
  • More Contractor Interest + High Bill Rate +  Low Supply = High Rate of Charlatans

Contractors do not have the labor pool to tap into to satisfy their contracts.  If you want to put on your cynic hat (all the Guerilla-CISO staff have theirs permanently attached with wood screws), you could say that the B|A|H report was trying to get the Government to pump more money into workforce development so that they could then hire those people and bill them back to the Government.  It’s a twisted world, folks.

Current contractor labor pools have some of the skills necessary for cybersecurity but not all.  More info in future blog posts, but I think a simple way to summarize it is to say that our current workforce is “tooled” around IT security compliance and that we are lacking in large-scale attack and defense skills.

Not only do we need more people in the security industry, but we need more security people in Government.  There is a set of tasks called “inherent government functions” that cannot be delegated to contractors.  Even if you solely increase the contractor headcount, you still have to increase the government employee headcount in order to manage the contractors.

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Posted in Outsourcing, Public Policy | 9 Comments »

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