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I’ve seen the scenario about a dozen times in the last 2 months–contractors and service providers of all sorts responding to the Government’s security requirements in the middle of a contract.  It’s almost reached the stage where I have it programmed as a “battle drill” ala the infantryman’s Battle Drill 1A, and I’m here to share the secret of negotiating these things.

Let’s see, without naming names, let’s look at where I’ve seen this come up:

• Non-Government Organizations that assist the Government with para-Government services to the citizens
• Companies doing research and development funded by the Government–health care and military
• Universities who do joint research with the Government
• Anybody who runs something that the Government has designated as “critical infrastructure”
• State and local governments who use Federal Government data for their social plans (unemployment system, food stamps, and ) and homeland security-esque activities (law enforcement, disaster response)
• Health Care Providers who service Government insurance plans

For the purposes of this blog post, I’ll refer to all of these groups as contractors or service providers.  Yes, I’m mixing analogies, making huge generalizations, and I’m not precise at all.  However, these groups should all have the same goals and the approach is the same, so bear with me while I lump them all together.

Really, guys, you need to understand both sides of the story because this a cause for negotiations.  I’ll explain why in a minute.

On the Government side:  Well, we have some people we share data with.  It’s not a lot, and it’s sanitized so the value of it is minimal except for the Washington Post Front Page Metric.  Even so, the data is PII that we’ve taken an anonymizer to so that it’s just statistical data that doesn’t directly identify anybody.  We’ve got a pretty good handle on our own IT systems over the past 2 years, so our CISO and IG want us to focus on data that goes outside of our boundaries.  Now I don’t expect/want to “own” the contractor’s IT systems because they provide us a service, not an IT system.  My core problem is that I’m trying to take an existing contract and add security requirements retroactively to it and I’m not sure exactly how to do that.

Our Goals:

• Accomplishing the goals of the program that we provided data to support
• Protection of the data outside of our boundaries
• Proving due-diligence to our 5 layers of oversight that we are doing the best we can to protect the data
• Translating what we need into something the contractor understands
• Being able to provide for the security of Government-owned data at little to no additional cost to the program

On the contractor/service provider side:  We took some data from the Government and now they’re coming out of the blue saying that we need to be FISMA-compliant.  Now I don’t want to sound whiney, but this FISMA thing is a huge undertaking and I’ve heard that for a small business such as ourselves, it can cripple us financially.  While I still want to help the Government add security to our project, I need to at least break even on the security support.  Our core problem is to keep security from impacting our project’s profitability.

Our Goals:

• Accomplishing the goals of the program that we were provided data to support
• Protection of the data given to us to keep the Government happy and continuing to fund us (the spice must flow!)
• Giving something to the Government so that they can demonstrate due-diligence to their auditors and IG
• Translating what we do into something the Government understands
• Keeping the cost of security to an absolute minimum or at least funded for what we do add because it wasn’t scoped into the SOW

Hmm, looks like these goals are very much in alignment with each other.  About the only thing we need to figure out is scope and cost, which sounds very much like a negotiation.

Hardcore Negotiation Skills photo by shinosan.

Little-known facts that might help in our scenario here:

• Section 2.4 of SP 800-53 discusses the use of compensating controls for contractor and service-provider systems.
• One of the concepts in security and the Government is that agencies are to provide “adequate security” for their information and information systems.  Have a look at FISMA and OMB Circular A-130.
• Repeat after me:  “The endstate is to provide a level of protection for the data equivalent or superior to what the Government would provide for that data.”
• Appendix G in SP 800-53 has a traceability matrix through different standards that can serve as a “Rosetta Stone” for understanding each other.  Note to NIST:  let’s throw in PCI-DSS, Sarbanes-Oxley,  and change ISO 17799 to 27001.

So what’s a security geek to do?  Well, this, dear readers, is Rybolov’s 5-fold path to Government/contractor nirvana:

1. Contractor and Government have a kickoff session to meet each other and build raport, starting from a common ground such as how you both have similar goals.  The problem really is one of managing each others’ expectations.
2. Both Government and Contractor perform internal risk assessment to determine what kind of outcome they want to negotiate.
3. Contractor and Government meet a week later to negotiate on security.
4. Contractor provides documentation on what security controls they have in place.  This might be as minimal as a contract with the guard force company at their major sites, or it might be just employee background checks and
5. Contractor and Government negotiate for a 6-month plan-of-action.  For most organizations considering ISO 27001, this is a good time to make a promise to get it done.  For smaller organizations or data , we may not even

Assumptions and dependencies:

• The data we’re talking about is low-criticality or even moderate-criticality.
• This isn’t an outsourced IT system that could be considered government-owned, contractor-operated (GO-CO)

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First, some links:

• Washington Technology
• Federal News Radio
• Federal Computer Week
• The RFI on FEDBIZOPS

Synopsis: DoD wants to know how its system integrators protect the “Controlled Unclassified Information” that they give them.  Hmm, sounds like the fun posts I’ve done about NISPOM, SBU and my data types as a managed service provider.

This RFI is interesting to me because basically what the Government is doing is collecting “best practices” on how contractors are protecting non-classified data and then they’ll see what is reasonable.

Faustian Contract photo by skinny bunny.

However, looking at the problem, I don’t see this as much of a safeguards issue as I do a contracts issue.  Contractors want to do the right thing, it’s just that they can’t decide if security is which of these things:

• A service that they should include as part of the work breakdown structure in proposals.  This is good, but can be a problem if you want to keep the solution cheap and drop the security services from the project because the RFP/SOW doesn’t specify what exactly the Government wants by way of security.
• A cost of doing business that they should reduce as much as possible.  For system integrators, this is key:  perform scope management to keep the Government from bleeding you dry with stupid security managers who don’t understand compensating controls.  Problem with this approach is that the Government won’t get all of what they need because the paranoia level is set by the contractor who wants to save money.

Well, the answer is that security is a little bit of both, but most of all it’s a customer care issue.  The Government wants security, and you want to give it to them in the flavor that they want, but you’re still not a dotorg–you want to get compensated for what you do provide and still make a profit of some sort.

Guess what?  It takes cooperation between the Government and its contractors.  This “Contractor must be compliant with FISMA and NIST Guidelines” paragraph just doesn’t cut it anymore, and what DoD is doing is to research how its contractors are doing their security piece.  Pretty good idea once you think about it.

Now I’m not the sharpest bear in the forest, but it would occur to me that we need this to happen in the civilian agencies, too.  Odds are they’ll just straphang on the DoD efforts. =)

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FAR: it’s the Federal Acquisition Regulation, and it covers all the buying that the government does.  For contractors, the FAR is a big deal–violate it and you end up blackballed from Government contracts or having to pay back money to your customer, either of which is a very bad thing.

In early August, OMB issued Memo 08-22 (standard .pdf caveat blah blah blah) which gave some of the administratrivia about how they want to manage FDCC–how to report it in your FISMA report, what is and isn’t a desktop, and a rough outline on how to validate your level of compliance.

Now I have mixed feelings about FDCC, you all should know that by now, but I think the Government actually did a decent thing here–they added FDCC (and any other NIST secure configuration checklists) to the FAR.

Check this section of 800-22 out:

On February 28, 2008, revised Part 39 of the Federal Acquisition Regulation (FAR) was published which reads:
PART 39-ACQUISITION OF INFORMATION TECHNOLOGY
1. The authority citation for 48 CFR part 39 continues to read as follows: Authority: 40 U.S.C. 121(c); 10U.S.C. chapter 137; and 42 U.S.C. 2473(c).
2. Amend section 39.101 by revising paragraph (d) to read as follows:
39.101 Policy.
* * * * *

(d) In acquiring information technology, agencies shall include the appropriate IT security policies and requirements, including use of common security configurations available from the NIST’s website at http://checklists.nist.gov. Agency contracting officers should consult with the requiring official to ensure the appropriate standards are incorporated.

Translated into English, what this means is that the NIST configurations checklists are coded into law for Government IT purchases.

This carries a HUGE impact to both the Government and contractors.  For the Government, they just outsourced part of their security to Dell and HP, whether they know it or not.  For the desktop manufacturers, they just signed up to learn how FDCC works if they want some of the Government’s money. 

Remember back in the halcyon days of FDCC when I predicted that one of the critical keys to success for FDCC was to be able to buy OEM desktops with the FDCC images on them.  It’s slowly becoming a reality.

Oh what’s that, you don’t sell desktops?  Well, this applies to all NIST configuration checklists, so as NIST adds to the intellectual property in the checklists program, you get to play too.  Looking at the DISA STIGs as a model, you might end up with a checklist for literally everything.

So as somebody who has no relation to the US Federal Government, you must be asking by now how you can ride the FDCC wave?  Here’s Rybolov’s plan for secure desktop world domination:

• Wait for the government to attain 60-80% FDCC implementation
• Wait for desktops to have an FDCC option for installed OS
• Review your core applications on the FDCC compatibility list
• Adopt FDCC as your desktop hardening standard
• Buy your desktop hardware with the image pre-loaded
• The FDCC configuration rolls uphill to be the default OS that they sell
• ?????
• Profit!

And the Government security trickle-down effect keeps rolling on….

Cynically, you could say that the OMB memos as of late (FDCC, DNSSEC) are very well coached and that OMB doesn’t know anything about IT, much less IT security.  You probably would be right, but seriously, OMB doesn’t get paid to know IT, they get paid to manage and budget, and in this case I see some sound public policy by asking the people who do know what they’re talking about.

While we have on our cynical hats, we might as well give a nod to those FISMA naysayers who have been complaining for years that the law wasn’t technical/specific enough.   Now we have very static checklists and the power to decide what a secure configuration should be has been taken out of the hands of the techies who would know and given to research organizations and bureaucratic organizations who have no vested interest in making your gear work.

Lighthouse From AFAR photo by Kamoteus.

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I’ve spent a couple of days traveling around to agencies to teach.  It was fun but tiring, and the best part of it is that since I’m not teaching pure doctrine, I can include the “here’s how it works in real life” parts and some of the BSOFH parts–what I refer to as the “security management heretic thoughts”.

Some basic statements, the rest of this post will explain:

• C&A is a commodity market
• Security controls assessment is a commodity market
• PCI assessment is a commodity market
• Most MSSP (or rather, Security Device Management Service Providers) services are commodity markets

Now my boss said the first one to me about 4 months ago and it really needed some time for me to grasp the implications.  What we mean by “commodity market” is that since there isn’t really much of a difference between vendors, the vendors have to compete on having the lower price.

Now what the smart people will try to do is to take the commodity service and try to make it more of a boutique service by increasing the value.  Problem is that it only works if the customers play along and figure out how your service is different–usually what happens is you lose in the market simply because now you’re “too expensive”.

Where Boutique Sits by miss_rogue.

Since the security assessment world is a services business, the only way to compete in a commodity market is to pay your people less and try to charge more. But oh yeah, we compete on price, so that only leaves the paychecks as the way to keep the margin up.

Some ways that vendors will try to keep the assessment costs down:

• Hire cheaper people (yes, paper CISSPs)
• Try to reduce the engegement to a formula/methodlogy (ack, a checklist)
• It’s all about billability:  what percentage of your people’s time is not billable to clients? 
• Put people on assessments who have tangential skills just to keep them billable
• Use Cost-Plus-Margin or Time-Plus-Materials so that you can work more hours
• Use Firm-Fixed-Price contracts with highly reduced services ($150 PCI assessments)

Now inside Government contracting, there’s a fact that’s not known outside of the beltway:  your margins are fixed by the Government.  In other words, they only allow you to have around a 13-15% margin.  The way to make money is that the pie is a much bigger pie, even though you only get a small piece of it.  And yes, they do look at your accounting records and yes, there are loopholes, but for the most part, you can only collect this little margin.  If you stop and think about it, the Government almost forces the majority of its contractors into a commodity market.

Then we wonder why C&A engagements go so haywire…

The problem with commodity markets and vulnerability/risk/pen-test assessments is that your results, and by extension your ability to secure your data, are only as good as the skills and creativity of the people that the vendor sends.  Sounds like a problem?  It is.

So knowing this, how can you as the client get the most out of your service providers? This is a quick list:

• Every year (or every other), get an assessment from somebody who has a good reputation for being thorough (ie, a boutique)
• Be willing to pay more for services than the bottom of the market but be sure that you get quality people to go along with it, otherwise you’ve just added to the vendor’s margin with no real improvements to yourself
• Get assessments from multiple vendors across the span of a year or two–more eyes means different checklists
• Provide the assessors with your own checklists so you can steer them (tip from Dave Mortman)
• Self-identify vulnerabilities when appropriate (especially with vulnerabilities from previous assessments)
• Typical contracting fixes such as scope management, reviewing resumes of key personnel, etc
• Get lucky when the vendor hires really good people who don’t know how much they’re really worth (that was me 5 years ago)
• More than I’m sure will end up in the comments to this post  =)

And the final technique is that it’s all about what you do with the assessment results.  If you feed them into a mitigation plan (goviespeak: POA&M) and improve your security, it’s a win.

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Well, this is a little bit of a departure from my usual random digital scribblings that I call a blog:  I partnered up with Vlad the Impaler and we created a slideshow complete with notes about why you should care about security and the Government and what you can learn from watching the Government succeed or fail.

The .pdf of the presentation is here.  Feel free to share with your friends, coworkers, and co-conspirators.

| View | Upload your own

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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:

1. 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.
2. 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.
3. 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.

Urban Cell-Phone Fire Myth photo by richardmasoner.  This myth is dispelled at snopes.com.

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.

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The US Army occassionally does things right.

Well, one of the things that they do right is training. Our training process for squad and above is mostly focused around the Observer-Controller (OC) and their value proposition (my MBA word for the day, TYVM). Whenever you are training, there is an OC tagging right along with you to assess what and why you are doing something and then make recommendations at the end.

 

Observer-Controllers hard at work, photo by David Axe

What an OC brings with them (aside from their 31337 BBQ Ski11z):

• Experience of having seen the same task done hundreds of times with various groups.
• A strong understanding of the doctrinally-correct way to do a task.
• Techniques to fill out where doctrine is not specific enough.
• Sometimes they have pre-written standard operating procedures that they will share with you.

What an OC will never do:

• Use you resources to support themselves.
• Own the solution space for you.
• Criticize you in front of your troops.
• Interfere with your ability to do your mission.

Hmmm, sounds like the things that a good auditor does.

Auditors are in a fantastic position to help the auditee because of the wide range of experience in how other companies have been doing the exact same thing that you are doing.  Point is, there is a level of collusion that needs to happen between the auditor and the auditee, and the extent of that collusion is really what we’re talking about when we start looking at Separation of Duties and similar things.

Over the years, auditors and auditees have had the nature of their relationship change numerous times. Around the time of Sarbanes-Oxley, the pendulum swung wildly the way of “no relationship no how” and now it’s slowly moving back to somewhere normal. Here’s a podcast with Michael Oxley talking about how auditors need to collude better with the auditee.  Disclaimer:  this is part of a series that is produced by my firm, but I had no part in this, Mkay?

Here in DC, we have a saying (Ok, I made it up my own self):  “Collusion is not just a technique, it’s THE technique.”  =)

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