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I’ve always wondered why I have yet to meet anyone in the Government using Database Activity Monitoring (DAM) solutions, and yet the Government has some of the largest, most sensitive databases around.  I’m going to try to lay out why I think it’s a great idea for Government to court the DAM vendors.

Volume of PII: The Government owns huge databases that are usually authoritative sources.  While the private sector laments the leaks of Social Security Numbers, let’s stop and think for a minute.  There is A database inside the Social Security Administration that holds everybody’s number and is THE database where SSNs are assigned.  DAM can help here by flagging queries that retrieve large sets of data.

Targetted Privacy Information:  Remember the news reports about people looking at the presidential candidate’s passport information?  Because of the depth of PII that the Government holds about any one individual, it provides a phenomenal opportunity for invation of someone’s privacy.  DAM can help here by flagging VIPs and sending an alert anytime one of them is searched for. (DHS guys, there’s an opportunity for you to host the list under LoB)

Sensitive Information: Some Government databases come from classified sources.  If you were to look at all that information in aggregate, you could determing the classified version of events.  And then there are the classified databases themselves.  Think about Robert Hanssen attacking the Automated Case System at the FBI–a proper DAM implementation would have noticed the activity.  One interesting DAM rule here:  queries where the user is also the subject of the query.

Financial Data:  The Government moves huge amounts of money, well into $Trillions.  We’re not just talking internal purchasing controls, it’s usually programs where the Government buys something or… I dunno… “loans” $700B to the financial industry to stay solvent.  All that data is stored in databases.

HR Data:  Being one of the largest employers in the world, the Government is sitting on one of the largest repository of employee data anywhere.  That’s in a database, DAM can help.

Guys, DAM in the Government just makes sense.

Problems with the Government adopting/using DAM solutions:

DAM not in catalog of controls: I’ve mentioned this before, it’s the dual-edge nature of a catalog of controls in that it’s hard to justify any kind of security that isn’t explicitly stated in the catalog.

Newness of DAM:  If it’s new, I can’t justify it to my management and my auditors.  This will get fixed in time, let the hype cycle run itself out.

Historical DAM Customer Base:  It’s the “Look, I’m not a friggin’ bank” problem again.  DAM vendors don’t actively pursue/understand Government clients–they’re usually looking for customers needing help with SOX and PCI-DSS controls.

London is in Our Database photo by Roger Lancefield.

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Paraben is a leading vendor for digital forensics products (http://www.paraben.com/). However, within this huge international market, Paraben specializes in digital forensic products for mobile devices such as PDA and phones. Paraben just recently released a very nice product called the Cell Seizure Investigator (CSI) Stick (http://www.csistick.com/index.html).

Aside from the overly-dramatic marketing embedded in the name of the product, this seems to be another solid addition to the Paraben product line. The device is designed to make a forensically correct copy of the data on your mobile phone–including call records, address books, and text messages. The devices look basically like a USB flash memory drive with the addition of an adapter/interface unit.

The copying process is largely automatic and the CSI Stick is quite reasonably priced at $99 -199, depending on the software bundle. The market reaction to this product is also quite positive. My friends in the industry who have used the device consider it an indispensable time-saving device. I can hardly wait until I get my have on one myself. In the past when, I was tasked to recover such data it was much more time consuming and hardware intensive process.

Equally fascinating, is the release (if you can call it that) of a product with a similar form-factor from Microsoft. The product is released on a flash drive and is called COFEE (Computer Online Forensic Evidence Extractor — http://www.microsoft.com/presspass/features/2008/apr08/04-28crantonqa.mspx).  Microsoft indicates that COFEE contains 150 commands that facilitate the collection of digital evidence from computers that it is physically connected to. In addition, COFEE can decrypt passwords, and collect information on a computer’s Internet activity, as well as data stored in the computer. Microsoft has indicated that COFEE has been made available to law-enforcement agencies only. And, according to one report, law-enforcement agencies in 15 nations have been provided with the device.

My initial reaction to this news was that it was not an unexpected development and that the announcement would be greeted with inevitable jokes about the need for Microsoft to also release a companion product called DONUTS. In fact, the reaction of the technical press has been largely negative and suspicious. Most of the concerns seem to center on privacy and individual rights. However, there isn’t a single capability associated with COFEE that I have been able to confirm, that doesn’t exist in some other commercial or open-source product. I do wish that I could get my hands on a trial or lender copy of COFFEE so that I could confirm this position.

Locksmith Sign photo by Meanest Indian.

While I admit that I have always been concerned about the safeguarding individual’s civil liberties, I am largely puzzled at the negative reactions. One element of the outcry that I do understand is an emotional one and that centers on the concept that a company that is paid to protect your secrets should not also be selling the tools and techniques to compromise those secrets. On an emotional level this makes sense.

However, the real world is very different. For example, every major automobile manufacturer cooperates with locksmiths to insure that there are low-cost and non-destructive means to circumvent you car locks in the event that you lock you keys in your cars or just loose you car key outright. Without getting into the details of defeating car locks, may automobile manufactures even provide specialized equipment and technical materials directly to locksmiths to facilitate this process.

If there are concerns that Microsoft my be caught in a ethical conflict of interest, we need to look at similar conflicts in other industries, and that’s food for thought.

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While I was slaving away last week, our friends over at NIST published a new version of SP 800-60.  Go check it out at the NIST Pubs Page.

Now for those of you who don’t know what 800-60 is, go check out my 3-part special on the Business Reference Model (BRM), a primer on how SP 800-60 aligning FIPS-199 with the BRM, and a post on putting it all together with a catalog of controls.

And oh yeah, the obligatory press reference: Government Computer News.

Data Release Show photo by Discos Konfort.

So deep down inside, you have to be asking one question by now:  “Why do we need SP 800-60?”  Well, 800-60 does the following:

• Level-sets data criticality across the Government:  Provides a frame of reference for determining criticality–ie, if my data is more important than this but less than this, then it’s a moderate for criticality.
• Counters the tendency to rate system criticality higher than it should be:  Everybody wants to rate their system as high criticality because it’s the safe choice for their career.
• Protection prioritization:  Helps us point out at a national level the systems that need more protection.
• Is regulations-based:  The criticality ratings reflect laws and standards.  For example, Privacy Act Data is rated higher for confidentiality.

All things considered, it’s a pretty decent systemfor Government use.

Now this is where I have a bit of heartburn with GRC tools and data classification in general in the private sector–they classify the wrong things.  How the vendors (not all of them, there is a ton of variation in implementation) want you to categorize your data:

• HIPAA-regulated
• PCI-DSS-regulated
• SOX-regulated
• All other data types

How your CISO needs to categorize data to keep the business afloat:

• Data that gets you paid:  If you’re a business, your #1 priority is getting money.  This is your billing/AR/POS data that needs to keep going.
• Data that keeps you with a product to sale over the next week:  usually ERP data, stuff that slows down the production line.
• Data that people want to rip off your customers:  hey, almost all the regulated data (PCI-DSS, HIPAA, etc) fits in here.
• Data where people will rip you off:  ie, your internal financial systems.  Typically this is SOX country.

I guess really it comes down to the differences between compliance and risk, but in this case, one version will keep you from getting fined, the other will keep your business running.

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And by “kerfluffle”, I mean these articles:

• GAO Privacy Report
• Technology Liberation Front
• Center for Democracy and Technology
• And how about an analysis of the Privacy Act from DOJ for background reasons?

Well, let’s talk about how privacy and the Government works with Uncle Rybolov (please hold the references to Old Weird Uncle Harold until we’re through with today’s lesson please).

We have a law, the Privacy Act of 1974.  Think about it, what significant privacy-wrenching activities happened just a couple of years prior?  Can we say “Watergate Scandal“?  Can we say “Church Committee“?  Suffice it to say, the early 1970s was an era filled with privacy issues and is where most of our privacy policy and law comes from.  Remember this for later:  this was the 1970’s!

Each of the various sections of the Privacy Act deals with a particular data type.  For instance, Title 13 refers to data collected by the Census Bureau when they’ll go count everybody in 2010.

The Privacy Act talks about the stuff that everybody in the Government needs to know about:  how you’re going to jail if you disclose this information to a third party.  For those of you who have ever been in the military or had to fill out a government form that required your social security number, the light in the back of your head should be going off right now because they all have the warnings about disclosure.

Remember to respect the privacy of the beach huts and chairs photo by Joe Shlabotnik

When it comes to IT security, the Privacy Act works like this:

• You realize a need to collect PII on individuals.
• You do a privacy impact assessment to determine if you can legally collect this data and what the implications of collecting the data are.
• You build rules about what you can do normally with the data once you have collected it.  This is called the “routine use”.
• You write a report on how, why, and about whom you’re collecting this information.  This is known as the “System of Record Notice”.
• You file this report with the Federal Register to notify the public.
• This IT system becomes the authoritative source of that information.

IE, no secret dossiers on the public.  We’ll suspend our disbelief in FISA for a minute, this conversation is about non-intelligence data collection.

Now the problem with all this is that if you stop and think about it, I was 1 year old when the Privacy Act was signed.  Our technology for information sharing has gone above and beyond that.  We can exchange data much much much more quickly than the Privacy Act originally intended.  As a result, we have PII everywhere.  Most of the PII is needed to provide services to the citizens, except that it’s a royal PITA to protect it all, and that’s the lesson of the past 2 years in Government data breaches.

Problems with the Privacy Act:

• The SORN is hard to read and is not easy to find.
• Privacy Act data given to contractors or “business partners” (aka, state and local government or NGOs) does not have the same amount of oversight as it does in the Government.
• Data given to the Government by a third-party is not susceptible to the Privacy Act because the Government did not collect it.  Wow, lots of room for abuse–waterboarding-esque abuse.
• Privacy Act procedures were written for mainframes.  Mainframes have been replaced with clusters of servers.  It’s easy to add a new server to this setup.  Yes, this is a feature.
• If you build a new system with the same data types and routine uses as an already existing SORN, you can “piggyback” on that existing SORN.
• It’s very easy to use the data in a way that isn’t on your “routine use” statement, thus breaking the entire privacy system.

Obviously, at this point, you should have gotten the hint that maybe we need to revise the Privacy Act.  I think GAO and OMB would agree with you here.

So, what alternatives do we have to the existing system?

• Make blanket data types and do a PIA and SORN on them regardless of where that data lies.
• Bend the Paperwork Reduction act and OMB guidance so that we don’t collect as much information.
• Make the Privacy Act more specific on what should be in SORN, PIA, and routine use statements.

To be honest, it seems like most of this is already in place, it just needs to get tuned a little bit so we’re doing the right things.  Once again, the scale of the Government’s IT infrastructure is keeping us from doing the right thing:    there isn’t enough time in the day to do PIAs on a per-server basis or to keep track of every little bit of data.  You have to automate our privacy efforts in some fashion.

And this is why, dear readers, I think the Government needs DLP solutions more than the private sector does.  Too bad the DLP vendors are stuck on credit cards and social security numbers.

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Interesting blog post at Freedom to Tinker about government releasing the raw data.  It makes the security geek in me cringe because well, most of the data that the government has is PII, and I know that the typical government reaction is to say “not only no, but h*ll no!!”  I mean, after all, most of our goal in the Government is to keep the data from reaching the citizens and evil-doers–giving away data is a cultural clash.

Yes, transparent government is a pretty good goal.  I think the authors of Freedom to Tinker have forgotten that not all Government data is fit for public consumption.  The problem is one of sanitization:  how do you clean all of the PII out of data before you release it to the public?  Not only that, but because of the size of the data sets, most likely you need an automated method to sanitize it.  I think that because of the sanitization factor that the Government would not gain that much efficiency by outsourcing the data presentation to others.

As with all things in security, this is nothing new.  There’s a little-known project (First Rule of “Fight Club” being what it is…) known as Radiant Mercury that does exactly this with classified data.  You can check out the basic concept in quasi-official presentations here (.pdf caveat) and here.

If we were going to make all this data available, we would need an unclassified version of Radiant Mercury to filter out all the PII and “Sensitive but Unclassified” bits.

Now as far as letting second parties build interfaces into the raw data, I’m torn on it.  On one hand, private industry can provide access to data “Now at Web 2.0 Speeds!” but on the other hand, then the Government loses control over the presentation and, by extension, accountability for the content.

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In building slides for our ongoing NIST Framework for FISMA class, I put together a deck of the ongoing Government security initiatives.  It’s plenty of stuff to keep you busy.

“Government Security System” Photo by Kahala

These are some of the more interesting initiatives and a brief description of them:

President’s Management Agenda Scorecard:  This is a quarterly red-yellow-green (hmm, wonder why nobody but the military uses black-red-yellow-green) scorecard on the various aspects of the agenda.  Security is represented as some of the values behind the E-Government score.  More specifically, OMB calls out the following in their FISMA report to congress:

To “get to green” under the E-Government scorecard, agencies must meet the following 3 security criteria:

• IG or Agency Head verifies effectiveness of the Department-wide IT security remediation process. (rybolov: Plans of Actions and Milestones)
• IG or Agency Head rates the agency C&A process as “Satisfactory” or better.
• The agency has 90 percent of all IT systems properly secured (certified and accredited). (rybolov: C&A does not always equate to “secured”, but is an indicator)

In order to “maintain green,” by July 1, 2008, agencies must meet the following security and privacy criteria:

1. All systems certified and accredited. (rybolov: same C&A caveat as before)
2. Systems installed and maintained in accordance with security configurations. (rybolov: lots of wiggle room here since it’s the agency’s standard except for the Federal Desktop Core Configuration)
3. Has demonstrated for 90 Percent of applicable systems a PIA has been conducted and is publicly posted. (rybolov:  PIA is a Privacy Impact Assessment.  It gets posted in the Federal Register as a public notification of what the Government is collecting and what the use is)
4. Has demonstrated for 90 percent of systems with PII contained in a system of records covered by the Privacy Act to have developed, published, and maintained a current SORN. (rybolov: System of Record Notice, this is what is filed with the Federal Register)
5. Has an agreed-upon plan to meet communication requirements for COOP and COG. (rybolov: Continuity of Government)

You can view the current scorecard and learn more about it at results.gov.

OMB Management Watch List:  This is a list of “at-risk” projects.  Security is one part of the list of risks, but for the most part this is a list of high-risk projects within the context of a program/project manager.  The security criteria for being on the Watch List are based on on IG assessments of:

• Certification and Accreditation
• Plan of Actions and Milestones
• Privacy Impact Assessment

 You can check out the most recent Watch List at OMB’s website.

Combined Catalog of Controls:  Superseding DoDI 8500.2 (DoD catalog of controls) and DCID 6/3 (intelligence community catalog of controls) with a reinforced SP 800-53.  Process flow would be along SP 800-37.  I’ve talked about this before.

Security Line of Business:  Agencies become subject-matter experts in an area and become a contractor to the other agencies.  Not a new concept, we’ve seen it elsewhere.

Privacy Management:  OMB Memo 07-16 lays out a privacy plan containing the following tenets:

• Breach Notification:  Requires each agency to have a breach notification policy
• SSN Reduction:  Each agency reduces the use of Social Security Numbers where not needed
• PII Reduction:  Restrict the collection of PII where not needed
• Rules of Behavior:  Rules for employees to follow when they deal with PII

SCAP and FDCC:  I’ve covered these in much detail. 

Trusted Internet Connections: This is a plan to reduce the number of Government internet connections to 50.  Even the most ardent OMB supporters have to agree that this is both a fairly arbitrary number, not achiveable in the next several years, and not even really a good idea.  You heard it here first, folks, but conventional wisdom says that 500 is a better, more realistic number for the time being, and that is the “real” number that OMB is considering.  The start of this is OMB Memo 08-05.

Einstein:  Basically a Government-wide IDS and SIEM run by US-CERT.  It’s offered under the Security Line of Business.  The good thing about Einstein is that it allows DHS to correllate events government-wide.

Air Force Cyber Command:  It’s provisional now, doesn’t have a permanent headquarters, and is trying to figure out what its mission is, but it’s here.  Gossip around town is that it’s focused on both defensive and offensive missions, although they pictures are all defensive-based.  There’s some information on their website, but be sure to read between the lines.  =)

Cyber Corps:  Scholarship program for college students (both post-grad and undergrad) with a public service obligation following graduation.  You can find out more here.

SmartBuy:  A GSA-run program to bulk-purchase commercial off-the-shelf software at a high-volume discount.  Think of it as a buyer’s club for software.  SmartBuy has disk-encryption software.  You can get more information on the GSA website.

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