I’m assuming the author wants us to read the title as “Things to Look Out For in Performing Risk Analysis” and not “Risk Management is Folly - Stop, Stop, Stop!” The former is fine, the latter isn’t supported by the evidence presented by the subjects of the article.
The subjects of the article are a good study from Wade Baker & Co. at Verizon, and a report from RSA’s Security for Business Innovation Council. Let’s take a look at each of these and examine why what they’re saying might contribute to poor risk management, shall we?

1.)  THE VERIZON REPORT

The Verizon report is an analysis of some 530 forensic investigations their company performed.  It is well worth your time as it’s chock full of interesting information.  As it relates to the Dark Reading piece, a coarse summary would be that “likelihood” is “different” for different people and so you can’t use the same “likelihood” across different industries.

Distilled through the lens of FAIR:

“different threat communities may be applicable based on Probability of Action factors which include: Value, Level of Effort and Risk (of Getting Caught).”

Or, even further distilled and in the words of my six year old son,

“Duh-uh”.

With regards to what I assume is the purpose of the article (What Doesn’t Work in Risk Analysis) this concept  seems just to rehash the old GIGO argument regarding risk analysis.  Great.  Can’t argue with that, nor it’s corollary QIQO (quality in, quality out).

But let me ask you -  is this really a problem common in your analysis?  Did reading this article make you go “Crap, we’ve been using data normalized across multiple industries in our analysis! They’re all wrong!”  Or have you already been accounting for the unique value proposition your company has to the specific threat community you’re worried about?  See, maybe I’m just not your average analyst, but even in my NIST/OCTAVE days, this has *never* been an issue for me.

Let me be specific, this is not a problem with Verizon’s very cool report.  It’s just that I don’t see what the big deal is.  This article is starting to feel like someone is running through the motions, trying to play the ” a crazy title gets people to read a boring article” game.

Speaking of cool reports - You know what would be cool?  I think it would be interesting to see is the quality of these companies’ “risk management process” established using good criteria,  and then correlated to the frequency and magnitude of real-world losses across the aggregate sample.  In other words, can we establish evidence that strong risk management practices not just reduce “risk” but also reduce actual incidents.

2.)  THE RSA COUNCIL “EXPLORES WHY LEGACY METHODS OF EVALUATING INFORMATION SECURITY RISK DON’T WORK IN TODAY’S CONNECTED WORLD, IN WHICH ANY NEW BUSINESS INNOVATION INHERENTLY CARRIES SOME LEVEL OF RISK TO INFORMATION.”

This report from the RSA council puts forth a seemingly obvious proposition, that risk must be balanced by reward.  Why is this news?  Now as I read the article it’s not clear if:

• The RSA Council is claiming that the CISO’s office should be the ones determining reward.  Absurd.

or

• Businesses aren’t doing a good job at determining risk and reward.

Let’s go with the latter.  So I’m pretty sure (good) businesses do a good job at estimating reward.  Businesses I’ve been a part of?  We LOVE(D) estimating reward.  We don’t tend to start projects all willy-nilly. No we tend to be careful to identify the size of the market and what it will cost to address the market.  So what could the problem be that this RSA council is trying to address?  Maybe it has to do with something like the following:

Yesterday, I got a demo of an IT-GRC application that shall remain nameless.  It seemed to be very good at the “C” bits - lots of information on regulations and expectations and even what sorts of controls would answer the regulations (which is goofy, but we’ll have to talk about that later).  It also gave you the ability to build workflow quite nicely.  But it measured NOTHING.  There really was no observable “G” and “R” was really Medium X Low X Low = High sorts of stuff.  So let’s use this relatively expensive tool as evidence of what your average CISO is armed with going into a Risk/Reward sort of meeting.  I imagine a nice board room with wood-grain paneling and glass bowls filled with little chocolate covered mints designed to give everyone involved in the meeting (CEO, CFO, CIO, CSO, VP S&M, etc…) a little sugar rush when needed and fresh breath.  The conversation goes a little something like this (apologies to Rich):

Business Guy Who Wants to Make Money Because That’s What Businesses Do: Based on market studies, we believe that initial gross revenues from the new product and technology rollout will be eleventy gazillion dollars based on a 37% market penetration in Scandinavia, alone.

CSO: Well now, we have a likelihood of “High” and a “C” impact of Medium, and an “I” impact of Low, and an “A” impact of “High” and because we are a (bank/hospital/retailer/basically any business that breathes anymore) we weight “C” by a factor of 2 - we multiplied those all together and got a “High”.

So can you guys delay the product rollout by 9 months and give me a bunch more money that’s not in the budget so that I can get this thing down to a “Medium”, please?

Again, I just don’t see the problem with Information Risk Management being that our businesses have no idea what the rewards of business might be.  Now maybe we need get a seat in that boardroom just to be able to talk about our “Mediums”, sure.  And maybe we’re infantile in our ability to describe our problem space.  But I cannot fathom that “Risk Management Doesn’t Work” because businesses haven’t been considering “reward”.

WHY RISK MANAGEMENT MAY  NOT BE WORKIN’ FOR YOU

Two meta-categories of causation:

• No skills

and/or

• No resources

Any ancillary “cause” can be mapped to one of these categories.  You could have significant resources but crappy models, and have conversations like our imaginary CSO, above.  You could have really good models and people trained and motivated to use them, but scarce time & money, so no conversation happens.

Now my question for you is - which does it make sense to acquire *first* to solve the “Why Risk Management Doesn’t Work” problems, skills or resources?

John talked about Microsoft’s mission, his perspectives on key industry trends and market opportunity; he touched on Cloud Computing and Virtualization and took some Q&A from the audience of Managed Service Provider executives.

One of his first proclamations - Microsoft has really embraced the heterogeneous environment. Really? How in the world is Microsoft going to help convince IT line managers, or mid level managers to believe this statement? I think they have a long way to go to achieve this vision with any credibility in the marketplace.  I do know that they are making small strides.

Microsoft has been widely credited with some very good blogs that are self critical and introspective. They have also been quite active in the standards boards within DMTF and many others such as Open WSMAN and CIMON (Open Pegasus). Microsoft in February published 30,000 pages detailed technical specifications – protocol documentation for Exchange, since that time they have published another 15,000 pages. They have had over 224,000 downloads since February 21, 2008. Thus they are trying to be more open by making some of these secret sauce protocol resources directly available on the web.

So for now, I will take a very cautious wait and see approach to this proclamation. Time will tell.

Trends

• Rapid growth continues
• Hosting Competition has a new face
  • Platform gorillas (amazooglesoft)
  • Ad supported Web 2.0 hosters (Google, Facebook,)
• Utility Cloud Computing models are expanding to non-traditional hosting companies
  • Wells Fargo vSafe - hard to believe that a big bank would start to offer a SaaS offering
  • New tools and markets digital ribbon, CohesiveIT

IDC Data shows that growth of SaaS ISV’s is the biggest layer of growth. The fastest growing services are complex, custom applications. IDC says this area will be bigger than the hosting area in the next 5 years. John said that Microsoft is spending a lot of time, money and energy on this right now.

John said:

“when Microsoft thinks about the building blocks that make-up the cloud, virtualization is a core piece of the puzzle. However you also need also identity services, Operating system with standard set of libraries to tap into… or remote storage that application developers will tap into.. Developers will consume these set of services, but you will also need a set of tools to manage your physical, virtual and geographically distributed datacenter infrastructure.” (that is where ScienceLogic comes in!!)

He went on to say,

“In some ways, virtualization enables decentralization – allows you to move from data centers, enables fast scaling out, business to move from on premise to the cloud and off again…. Automation is very important – this will help you scale your business – this is core to your future success.”

He talked about a new breed of knowledge worker: He called them Digital Natives (compared to grey haired guys like me who are left out of this category).

Definition of a Digital natives? A young adult who has grown up with cellphone, web based applications, Facebook account, as their primary mode of communications.

John commented that we are 5 years into a 10 year journey. Only 12% of all servers in the world are virtualized today… in the next 4 years it will double to 25%. This is the time to think through how this business will affect you.

‘Virtualization without good management is more dangerous than not using virtualization in the first place.” Thomas Bittman, Analyst Gartner

Patching and provisioning nightmare – no scalable administration – sprawl chaos.

John posed a question to the audience: How do you partner to provide the ISV support in application development with specific market needs… partner by keeping the hosting to SaaS solution providers up and running and provide the quality of service that their customers expect…. Complimentary services of storage and backup is a big win with a huge market-upside over the next 5 years..

John said that Microsoft continues to make  huge investments with Managed Service Providers.

• Investing in the windows hosting platform
• Hyper V and SQL2008 GoLive program - getting beta code out to service provides to find as many bugs as early as possible.
• Software + Services (S+S) incubation center program
• Partnering for cloud platform market offers
• Cloud platform guidance and best practices

During the Q&A, David Burns from Cincinnati Bell asked the very best question… “when are you going to make it easier for the Service Provider market to deal with the Microsoft Service Provider Licensing Agreement (SPLA) quarterly statistics pull and change the SPLA pricing to be more efficient and creative for the new Virtualization and Cloud offerings you have talked about?”

John’s response: “We hear your frustrations loud and clear and are working on some new ideas for the future version of SPLA.” My interpretation – “Dear Service Providers don’t expect anything new or easier to deal with in the next 6 months!”

His closing remarks: “Cloud is evolving = very early stages, lots of hype, but think of how this evolution will effect your business and how you can plug into it.”

I have to admit that I was already a fan of Collins’ quantitative style blended with clever insight, but this was the first time that I had seen him in person, and he was just spectacular. He has a vivid, animated way of telling a story, and had a great sense of humor. This combination of presentation skill was put to immediate use with his first statement drawing a hearty laugh from the audience full of entrepreneurs.

“How many of you in the room are constitutionally unemployable?”

Much of his remaining presentation provided interesting stories and insight from the research that he has done to understand the make-up of exceptional companies.

As Jim said, he has spent years studying the contrast between average companies and exceptional companies. They faced the same set of variables… similar economic conditions, similar competition for top human resources, and a similar set of huge unknowns.

What is the single biggest element of difference?

Not a function of the cards you are dealt, or circumstance… it is conscious choice and discipline.

Jim’s key principles & disciplines that have come from the studies we have worked on:

1. Building greatness is a cumulative never ending process! The idea that no matter how exceptional, you are always only relatively as good as to what you can do next.
2. Most overnight successes are 20 years in the making…. Wal-mart  took 13 years to get to 125 stores. Starbucks required 17 years to get to 38 stores.

“If you start to break Packard’s law, and there are very few laws of business, it is like breaking a law of physics for building great companies.” - David Packard (Co-founder of HP)

If you allow growth to exceed your ability to get enough of the right people to fill the key seats to execute on the growth brilliantly, you will fall as surely as a stone dropped from your hand. This is one of those timeless truths that extends beyond technology and economics.

The number one constraint on growth and sustained success…

An ability to get enough of the right people in the key seats to achieve that sustained growth.

The discipline that WHO comes before WHAT. Collins always kept coming back to the “who” thing over and over again. He said, “The more turbulent the world, (given the great current economic uncertainty of our financial system) the more important this issue is.”

A question from the audience came near the end of his session… How do you figure out who are the right people to put in key seats on the bus?

Collins responded with “Given that I stand here amidst a room full of unmotivated people… the right people are self motivated, self disciplined, self managed, The task is not to motivate unmotivated people, the task is not to have to manage people… self motivated, figured it out from there… self motivated people don’t need tons of management … when you have to start managing, you know that you have the wrong person at the task.”

Final thoughts:

Greatness is not a function of circumstance. Greatness is a function of conscious choice and discipline. It is not a matter of circumstance, it is one of choices.

I believe that every one of the Inc. 500 companies that I met at this conference achieved the list because they did not embrace the status quo. Incredible passion, an unwillingness to accept failure and an excessive and compulsive willingness to solve customer’s problems were key ingredients in the business building formula for the entrepreneurs that were at the conference.

• Moderator: Jim Metzler, Vice President, Ashton, Metzler & Associates
• Rowan Snyder, CIO, KPMG
• David Michael, CIO, United Business Media Group
• Joanna Young, Chief Information Officer, Corporate Information Systems & Enterprise Services, Liberty Mutual

Jim: Is the CIO a technical job anymore? For example, inside Liberty there are business projects with an IT component.

Joanna: We are organized to partner with internal business clients or vendors who provide objectives and business requirements. We strive to figure out the smallest amount of an IT investment we can make to get this to work.

Rowan: We have both. Part of the dilemma is that the thing that sells the best is fear. I don’t want to use that to get business.

Joanna: One good example is security from an application perspective. It’s hard to talk about security investments in business terms. We put it into terms like “this is what it will cost us if we DON’T do this.” For example, a solution for spam required us to do research into what it was costing us overall. Once we put it together, the business was all for it. You have to put your business hat on and think “how can I make this important for a businessperson?” If you can’t, you may need to ask yourself why you’re pushing services on them that they may not need.

Jim: Can you give us insight into business-IT alignment? What about governance?

Rowan: Governance is the hardest part of IT. It’s not like the technology is easy. If it’s a business project with an IT component, I don’t usually get involved. It comes down to overall budget. The infrastructure we own and let people know exactly what it will cost to do it. We are a distributed IT firm, there are multiple groups. This is the most distributed and risk-prone organization I’ve worked in. It can be difficult for the business to exert control. It demonstrates risk, in security, compliance, methodologies, etc.

Joanna: Governance has become a word that nobody wants to use. It suddenly implies that IT is the holder of all the money and they are the ones that get to decide. We stopped using that word and position IT as a strategic business partner.

David: We have a highly decentralized IT set-up. We have about 600 globally and around 40 in the headquarters. We have 10 CIOs for each division, and within each division it is decentralized. We try to run each unit as autonomous. This is a close alignment with IT and business. However, then the problem of how do you have commonality between divisions and collaboration?

Jim: How can you minimize risk in distributed environment using standards and procedures?

David: The reality is it can be impractical for an organization. You end up with a patchwork of platforms and technologies. We have to accept that we’ll have multiple solutions. We can attempt to push a standard, but overall have a much more relaxed approach to manage everything. There is a lot of equality between divisions in what they can choose to purchase.

Joanna: Standards are easier to apply the further down the staff you are. The most important thing with any of this is to understand why you are making the decisions. If there is a process and pros and cons are identified, there is a clear record of why decisions were made.

Audience Poll: Everyone raised their hand that MORE standards were needed.

Audience Question: Are there inefficiencies in the data center in terms of energy and green IT? What are you doing about it?

Joanna: Everyone focuses on cars for carbon footprints. But, it’s really buildings…and then data centers. The data center has the same importance as any other efficiency. They need to be running as cheaply as possible. Corporations have a responsibility to make sure they are energy efficient.

Rowan: We recently did a carbon footprint analysis, and found that half of carbon comes from electricity, with half of that from the data center.

David: Every company does have a responsibility to look at its carbon emission globally. Consider international travel, flying, etc. As much as possible, we are not building data centers. We are using other people’s data centers in an effort to get out of the data center business.

Audience Question: How do you balance the good from standards with agile development and possible roadblocks?

Joanna: Luckily agile development is under the CIO’s control. You can see the lifecycle and savings that occur. When I look, I check what the standards are that I’m measuring by.

Jim: Does web 2.0 have any business meaning in your environment? If so, what are you doing about it?

Joanna: I’ve been in IT for 20 years. It’s another component to business IT investment, and has to be presented as such. As IT professionals we have a responsibility to identify what Web 2.0 is, and then translate to see if there is anything the company should be doing with it. Monitor it based on your current portfolio, and consider its impact.

David: It’s pretty important to our business as a media company. I don’t think it means one thing, it’s a term people use to talk about the web and what’s going on online. From mobile, to ajax, cloud computing or mashups - you can draw multiple conclusions. More and more business is being done online. We have a lot of growth opportunities online.

Rowan: Compliance, security, and privacy issues just explode with Web 2.0.

Which of the following initiatives are likely to be a major telecommunications technology related priority for 2007? Mobility is a huge issue.

We’re starting to see traction with mobility.

• The evolution of enterprise mobility:
  • Voice –> messaging –> e–mail –> web, –> business applications –>  instant messaging/presence –> what’s next?
• Cell phone to Smartphone:
  • 1G –> 2G –> 3G

Converging IT Responsibilities

Collaboration, Web/Internet, Desktop Computer, Deskphone/PBX, Mobile Phone and Applications. All of this is under the umbrella of IT. IT departments are not a single cohesive unit where everyone gets along. They have different motivations, budgets, goals, etc.

BlackBerry manages all of these responsibilities in one, forcing these departments to collaborate and work together. This is key for interoperability between these systems, knowing how they work together.

Desktop capabilities are expected in mobility:

• Information
• Collaboration
• Voice
• Transactions
• Presence
• Application

Mobile devices are fundamentally changing the pace of which we all work. You can reach anybody at anytime. This changes business.

All of this is working with data that is behind a corporate firewall.

The big change in IT is that for almost any industry now, the data that you have and you manage is a core corporate asset. It doesn’t matter whether you’re in manufacturing, logistics, or a bakery. Information is king. This has the benefit of moving IT up to a C-level position. You are a core part of your business success. This has benefits, and also added stress.

Voice is still the “killer app” for mobility. Deskphones and smartphones need to overlap into a mobile voice system.

Another up and coming technology is the mobilization of enterprise applications. This provides the ultimate user experience. For example, Blackberry has mobilized the SAP Business Suite on BlackBerry smartphones. SAP CRM access is as seamless and intuitive as email on BlackBerry and incorporates push, alerting, security, GPS, Wi-Fi and media.

Enterprise grade platforms will extend core competencies of enterprise systems to mobile environments.

• Secure
• Reliable
• Manage
• Control
• Administration
• Standardize

Conclusion:

Putting it together: integrating the wireless capabilities of today into the business tools of tomorrow.

That being said, there are some interesting implications that XSS Filter and other user-specified defenses have for the SDL. Given that XSS Filter is effective in stopping many types of reflected XSS attacks, should we relax the SDL coding and testing requirements around server-side XSS defense? Of course not. For one reason, the SDL requirements are effective in preventing forms of XSS that XSS Filter does not address, like persistent XSS. For another, not everyone uses IE 8. If we were to relax server-side requirements now, we would jeopardize IE 7 users, as well as Firefox, Safari, Opera, Chrome, and all the other browsers’ users.

But what if these conditions change? What if David and others on the security science team develop a new version of XSS Filter that’s effective against all forms of XSS? And what if all the browser manufacturers develop similar technology and implement it in their browsers? (Or alternatively, what if every user on the planet switches to IE 8? ☺) Then would we relax the server-side XSS defense requirements? Yes, we probably would.

I’ve always been more of a security pragmatist than a security purist. While the security purist in me would want to keep the requirements around to prevent developers from falling back into bad habits, the security pragmatist in me would recognize that development teams have a limited amount of bandwidth, and making them defend against rare, obscure vulnerabilities is a poor use of their time. Unfortunately, we’re not likely to face this scenario any time in the near future, so the SDL will continue to require server-side input validation and output encoding to prevent XSS attacks.

We now return you to your regularly scheduled development-focused blog.