I’d love to have another blog even more specific - “Ok, that Assurance is Evidence Of What, Exactly?

Today he has a great article called:

What’s the matter with Risk Management?

And “in short, it’s everything.” It pretty much sums up why I had to grow to re-evaluate how our industry does risk, risk management, approaches controls & vulnerability and find a new way.   A couple of things jump out at me in reading Chris’ article:

1.)  Just because that Deming cycle sucks and is full of unknowns doesn’t mean “risk” doesn’t exist, nor that it isn’t of primary importance. Nor does it mean that in the absence of model & methodology, we won’t be “doing” risk analysis anyway - just in an ad hoc method and completely from “the gut”.

Our industry calls these unstructured risk analysis “Best Practices”, as it’s an easy and convenient way of sweeping the unknowns under the rug of bureaucracy and enforcing it via peer pressure.

2.)  What this “suckiness” does mean is that your model and methodology aren’t helping you. As Chris intimates, there is too much uncertainty in the inputs for his model (they are, in the language of Bayesians - too subjective to be useful priors).

Take for example how we might be approaching the “controls” part of our analysis.  Chris writes:

“2. What are the controls that we have to employ?
800-53, ISO 27001, PCI, etc.

Still kinda good, but we basically know that ISO is relatively voluntary and NIST supplies a control catalog and not policies. So here we have to take the control catalog, and mash our policies into it.”

I wouldn’t call this “kinda good” at all :)  These control catalogs only provide a hierarchy within which to look for evidence of  our ability to resist an attacker.  They are incapable of making any claim about the effectiveness of the controls when they are operated at 100% efficiency, or more importantly, what % efficiency our specific organization operates at.

Let’s use Chris Hayes’ Initech as our fictional example.

Initech has a control (a back door on a loading dock).  Now the locks on the door are 100% capable of locking the door.  This is different than saying that they are capable of frustrating all but the top 5% of lockpicking burgalars.  It is also diffferent than saying that in a sample of several “walk around audits” the doors are left open 20% of the time (they are not in compliance with policy 100% of the time).  Even worse, that 80% of the time the door is not propped open?  Yeah, tailgating is a known issue.

So we have several different variables here that we need to account for (and it’s just a door).  But the analogy stands that most “risk management” methodologies are “We have a door, yes/no?” And most GRC platforms, when asked for their “opinion” will simply say “door is needed” or, even worse, “a door policy is needed”.

3.)  Criticality and the Source of Value is all messed up in these Risk Management models.

Chris writes:

Someone wants me to tell them which boxes are more critical than others. This is mainly because of budgetary or operational reasons. To which I usually say “All of them, it is a system after all”.

This literally made me laugh out loud.  And this sort of “rate the firewall as Risk = 500 but rate the actual business application as Risk = 157″ thing is also endemic.  Now Chris is very smart here.  He correctly identifies that the value is tied to the business process the systems support, and not to a specific box.  Oh, we scan at the specific box level - but because of the nature of systemic failures - all the boxes in the process are inexorably interrelated.

One of the reasons I really like FAIR is that the losses are quantified (or qualified) based not on some amorphous value of the box or the process itself, but losses are linked to the actions that the threat will take. Take systems in a highly regulated industries as an example.  Usually the most probable losses aren’t due to system compromise per se, but in the disclosure the compromise causes (regulators are a threat source, after all).  But many “risk management” methodologies will say “online banking is worth $2 billion, the value of the systems is therefore $2 billion”.  And suddenly we’re telling executive management that there’s a 60% probability that they’ll lose $2 billion.

4.)  If the primary source of prior information for your “risk management” methodology is a vulnerability scanner - you’re doing it wrong.  Chris writes:

So we ran a scan and now we have a report. A snapshot in time to make all decisions. Where did these vulnerability ratings come from? Do I even know if my system is at risk? What if I spend my time on vulnerabilities that have no threat?

So first, my thoughts are that actual “vulnerability” must be a comparison of the force a threat can apply, and our ability to resist that force (this is a probability statement, btw).

Changing your thinking about vulnerability now helps us understand the problem in several new ways.  First, you can start to divorce yourself from the scanner.  After all, the scanner is simply providing you with current state information that is usually just relevant variance from policy. It doesn’t really tell you about real “weakness in a system” because the system is an interrelated mess of people, processes and IT assets.

5.)  Finally, most “risk management” approaches just *don’t* do a good job of helping us understand the how’s and why’s of managing risk. In the past, I’ve referred to these standards as really being “issue management” because they are at their heart, an act of discovery - a formal process around gathering prior information.  They are not, in and of themselves, capable of linking the issues discovered to the root cause.  And these root causes?  Yeah, they’re the things that create “risk”.  Not a threat, not a vulnerability, not the existence of an asset - the amount of risk that we have stems from our capability to manage it.

So Chris, I completely agree - but I wouldn’t give up yet.  There actually are a few of us who are focused on what you suggest:

Where to go from here: A fundamental revamp of how to deal with Risk. Where risk professionals focus on the treating the sickness and not the symptoms, and come up with some new success/actionable metrics.

Chris, there’s nothing I want to do more than that.

If you look at the news, you’ll see layoffs, buyouts, bankruptcy, going-out-of-business– there are a lot of companies in trouble right now

Ebay — laying off around 1500 workers.

Corbis — Cutting 170 Jobs, as its start-up rival Photoshelter closes its doors.

Washington Mutual in trouble

HP cutting 24,600 jobs

B of A – stocks tumble as the bank buys Merrill Lync

Fannie Mae and Freddie Mac taken over by the Feds a couple weeks back

I’ve read in many places that even though the economy is headed under, tech is still going strong. But with fewer jobs overall and less confidence, tech is sure to take a tumble as well. These are tough times that aren’t going to be solved by going out and buying buttons for your favorite political candidate.

With all this talk and reporting about security concerns, lets change the channel for a moment and assess the potential security benefits of Cloud Computing.

In my view, there are some strong technical security arguments in favour of Cloud Computing - assuming we can find ways to manage the risks.

With this new paradigm come challenges and opportunities.  The challenges are getting plenty of attention - I’m regularly afforded the opportunity to comment on them, plus obviously I cover them on this blog.  However, lets not lose sight of the potential upside.

In this post, I walk through seven technical security benefits.  Some are immediate, others may arise over time and have conditions attached (some unstated for the sake of brevity).  However, I’m including the longer-range benefits now to raise awareness.  Some of the outcomes listed are available today without the Cloud, but they are either complex and slow to implement (and thus less likely to happen) or prohibitive for capital cost reasons.  I don’t claim this is a definitive list - it reflects where my thinking is today.

Some benefits depend on the Cloud service used and therefore do not apply across the board.  For example; I see no solid forensic benefits with SaaS.  Also, for space reasons, I’m purposely not including the ‘flip side’ to these benefits, however if you read this blog regularly you should recognise some.

On a sidenote, I believe the Cloud offers Small and Medium Businesses major potential security benefits.  Frequently SMBs struggle with limited or non-existent in-house INFOSEC resources and budgets.  The caveat is that the Cloud market is still very new - security offerings are somewhat foggy - making selection tricky.  Clearly, not all Cloud providers will offer the same security.

Seven Technical Security Benefits of the Cloud

1. Centralised Data

• Reduced Data Leakage: this is the benefit I hear most from Cloud providers - and in my view they are right.  How many laptops do we need to lose before we get this?  How many backup tapes?  The data “landmines” of today could be greatly reduced by the Cloud as thin client technology becomes prevalent.  Small, temporary caches on handheld devices or Netbook computers pose less risk than transporting data buckets in the form of laptops.  Ask the CISO of any large company if all laptops have company ‘mandated’ controls consistently applied; e.g. full disk encryption.  You’ll see the answer by looking at the whites of their eyes.  Despite best efforts around asset management and endpoint security we continue to see embarrassing and disturbing misses.  And what about SMBs?  How many use encryption for sensitive data, or even have a data classification policy in place?
• Monitoring benefits: central storage is easier to control and monitor.  The flipside is the nightmare scenario of comprehensive data theft.  However, I would rather spend my time as a security professional figuring out smart ways to protect and monitor access to data stored in one place (with the benefit of situational advantage) than trying to figure out all the places where the company data resides across a myriad of thick clients!  You can get the benefits of Thin Clients today but Cloud Storage provides a way to centralise the data faster and potentially cheaper.  The logistical challenge today is getting Terabytes of data to the Cloud in the first place.

2. Incident Response / Forensics

• Forensic readiness: with Infrastructure as a Service (IaaS) providers, I can build a dedicated forensic server in the same Cloud as my company and place it offline, ready for use when needed.  I would only need pay for storage until an incident happens and I need to bring it online.  I don’t need to call someone to bring it online or install some kind of remote boot software - I just click a button in the Cloud Providers web interface.  If I have multiple incident responders, I can give them a copy of the VM so we can distribute the forensic workload based on the job at hand or as new sources of evidence arise and need analysis.  To fully realise this benefit, commercial forensic software vendors would need to move away from archaic, physical dongle based licensing schemes to a network licensing model.
• Decrease evidence acquisition time: if a server in the Cloud gets compromised (i.e. broken into), I can now clone that server at the click of a mouse and make the cloned disks instantly available to my Cloud Forensics server.  I didn’t need to “find” storage or have it “ready, waiting and unused” - its just there.
• Eliminate or reduce service downtime: Note that in the above scenario I didn’t have to go tell the COO that the system needs to be taken offline for hours whilst I dig around in the RAID Array hoping that my physical acqusition toolkit is compatible (and that the version of RAID firmware isn’t supported by my forensic software).  Abstracting the hardware removes a barrier to even doing forensics in some situations.
• Decrease evidence transfer time: In the same Cloud, bit fot bit copies are super fast - made faster by that replicated, distributed filesystem my Cloud provider engineered for me.  From a network traffic perspective, it may even be free to make the copy in the same Cloud.  Without the Cloud, I would have to a lot of time consuming and expensive provisioning of physical devices.  I only pay for the storage as long as I need the evidence.
• Eliminate forensic image verification time: Some Cloud Storage implementations expose a cryptographic checksum or hash.  For example, Amazon S3 generates an MD5 hash automagically when you store an object.  In theory you no longer need to generate time-consuming MD5 checksums using external tools - its already there.
• Decrease time to access protected documents: Immense CPU power opens some doors.  Did the suspect password protect a document that is relevant to the investigation?  You can now test a wider range of candidate passwords in less time to speed investigations.

3. Password assurance testing (aka cracking)

• Decrease password cracking time: if your organisation regularly tests password strength by running password crackers you can use Cloud Compute to decrease crack time and you only pay for what you use.  Ironically, your cracking costs go up as people choose better passwords ;-).
• Keep cracking activities to dedicated machines: if today you use a distributed password cracker to spread the load across non-production machines, you can now put those agents in dedicated Compute instances - and thus stop mixing sensitive credentials with other workloads.

4. Logging

• “Unlimited”, pay per drink storage: logging is often an afterthought, consequently insufficient disk space is allocated and logging is either non-existant or minimal.  Cloud Storage changes all this - no more ‘guessing’ how much storage you need for standard logs.
• Improve log indexing and search: with your logs in the Cloud you can leverage Cloud Compute to index those logs in real-time and get the benefit of instant search results. What is different here?  The Compute instances can be plumbed in and scale as needed based on the logging load - meaning a true real-time view.
• Getting compliant with Extended logging: most modern operating systems offer extended logging in the form of a C2 audit trail.  This is rarely enabled for fear of performance degradation and log size.  Now you can ‘opt-in’ easily - if you are willing to pay for the enhanced logging, you can do so.  Granular logging makes compliance and investigations easier.

5. Improve the state of security software (performance)

• Drive vendors to create more efficient security software: Billable CPU cycles get noticed.  More attention will be paid to inefficient processes; e.g. poorly tuned security agents.  Process accounting will make a comeback as customers target ‘expensive’ processes.  Security vendors that understand how to squeeze the most performance from their software will win.

6. Secure builds

• Pre-hardened, change control builds: this is primarily a benefit of virtualization based Cloud Computing.  Now you get a chance to start ’secure’ (by your own definition) - you create your Gold Image VM and clone away.  There are ways to do this today with bare-metal OS installs but frequently these require additional 3rd party tools, are time consuming to clone or add yet another agent to each endpoint.
• Reduce exposure through patching offline: Gold images can be kept up securely kept up to date.  Offline VMs can be conveniently patched “off” the network.
• Easier to test impact of security changes: this is a big one.  Spin up a copy of your production environment, implement a security change and test the impact at low cost, with minimal startup time.  This is a big deal and removes a major barrier to ‘doing’ security in production environments.

7. Security Testing

• Reduce cost of testing security: a SaaS provider only passes on a portion of their security testing costs.  By sharing the same application as a service, you don’t foot the expensive security code review and/or penetration test.  Even with Platform as a Service (PaaS) where your developers get to write code, there are potential cost economies of scale (particularly around use of code scanning tools that sweep source code for security weaknesses).

Your Thoughts?

What benefits do you see that I haven’t included in the above list?  Where do you agree/disagree and importantly, why?

The United States Office of Management and Budget has recommended the use of cost-benefit assessment for all proposed federal regulations. Since 9/11 government agencies in Australia, United States, Canada, Europe and elsewhere have devoted much effort and expenditure to attempt to ensure that a 9/11 type attack involving hijacked aircraft is not repeated. This effort has come at considerable cost, running in excess of US$6 billion per year for the United States Transportation Security Administration (TSA) alone. In particular, significant expenditure has been dedicated to two aviation security measures aimed at preventing terrorists from hijacking and crashing an aircraft into buildings and other infrastructure: (i) Hardened cockpit doors and (ii) Federal Air Marshal Service. These two security measures cost the United States government and the airlines nearly $1 billion per year. This paper seeks to discover whether aviation security measures are cost-effective by considering their effectiveness, their cost and expected lives saved as a result of such expenditure. An assessment of the Federal Air Marshal Service suggests that the annual cost is $180 million per life saved. This is greatly in excess of the regulatory safety goal of $1-$10 million per life saved. As such, the air marshal program would seem to fail a cost-benefit analysis. In addition, the opportunity cost of these expenditures is considerable, and it is highly likely that far more lives would have been saved if the money had been invested instead in a wide range of more cost-effective risk mitigation programs. On the other hand, hardening of cockpit doors has an annual cost of only $800,000 per life saved, showing that this is a cost-effective security measure.

Hardening cockpit doors has the highest risk reduction (16.67%) at lowest additional cost of $40 million. On the other hand, the Federal Air Marshal Service costs $900 million pa but reduces risk by only 1.67%. The Federal Air Marshal Service may be more cost-effective if it is able to show extra benefit over the cheaper measure of hardening cockpit doors. However, the Federal Air Marshal Service seems to have significantly less benefit which means that hardening cockpit doors is the more cost-effective measure.

Recently I spent one week at a customer in a hotel where the staff obviously was hosting nightly parties down at my end of the hall- from about 2:00am - 5:30am each (yes- every) night I was there. The hotel I’m in tonight has no elevator. Yeah. @#$! That’s what I said. Twice in the past 10 days or so, I’ve been in really nice resort-hotels, so I’ve had the whole spectrum this month and last.

For me, sometimes it’s the little things… I really like it when hotels have conditioner, instead of just shampoo. I like space- so a nice work area is important to me. Of course a big soft bed and plenty-o-pillows is a key ingredient. A whirlpool or jetted tub (in the room) is icing on the cake. Exercise rooms are good, although half the time I’m too tired when traveling or have work to do (I know- excuses, excuses ;). Convenience is also a biggie- I had a run in Las Vegas where *every* room I had felt like it was a 10-minute walk just to the elevators. When I’m on-site for a customer, I also love the hotels with the do-it-yourself breakfast- I can go when I want and grab something before heading out for the day. I love the little lighted makeup mirrors… and of course a full-length for checking out the wardrobe. Plugs! I love lots of plugs. I like hotels that secure the outer doors early and require a key for access to various parts of the building.

Sometimes it’s the bigger things… Hotels with outside-facing doors make me paranoid, and obviously those in neighborhoods where your rims may disappear is not good either. I hate hotels that MAKE me valet park my car. It’s my car, my keys, I park it and I keep the keys- that’s my rule. (My Dad taught me a little trick of telling the valet boys that it’s a company car and against corporate policy for valet- it works!)

Traveling techies sometimes have unique needs or requests, and many of the ‘good list’ is universal for all traveler types.

So, those are some items from my little list… What about you- what do YOU look for in a good hotel?

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