Case in point is the jury trial of Julie Amero, a schoolteacher who was charged with felony for allegedly showing porn to her class–when in fact the porn sites were popups caused by malware on the classroom computers that popped up while she was teaching:

a series of incompetent computer experts and overzealous prosecutors tried to claim that the pornography that appeared on the school computer browser was deliberately viewed. In reality the computer was infected with a browser hijack or other form of malware nastiness that launched a flood of porn pop-ups. There was an outpouring of support and some technical folks like Alex Eckleberry, who led an effort to prove that Julie was innocent of the charges

After a long trial, Amero has finally been vindicated. But she has still lost those years of her life spent on the case, her teaching credential, and is being charged a $100 fine. While her trial might be over, her personal troubles aren’t.

The latest set of miscreants operates under the brand “goodeyeforlinks.com” and claim to “use white hat SEO techniques in order to get high quality, do-follow links to your website”. They also claim to be “professional” which in this case must mean you pay for their services, since sending out bulk unsolicited email is anything but professional.

Nevertheless, although their long term aim may indeed be to make money from legitimate, albeit foolish, businesses seeking a higher profile, the sites they have been promoting so far are anything but legitimate. In fact they’ve been fake sites covered with Google adverts (so-called “Made for AdSense” (MFA) sites).

They started by asking me to link to “entovation.net” which they claim is “page rank 3″. In fact it is page rank 3 (!) and a blatant copy of http://www.acentesolutions.com which appears entirely genuine (albeit only page rank 1). They have also been promoting “poland-translation-services.com“, which claims to be a site offering “A large team of 2,500 translators specializing in each sector, located in over 30 countries” …

However, this site is clearly fake as well. I haven’t tracked down where it all comes from, but much of this page comes from this Argentinian page, the text of which has been pushed through Google’s Spanish to English translation tools… which sadly (for example) renders

Comentarios: Se considera foja al equivalente a 500 palabras. Si el documento a traducir es menor a una foja, se lo considerará como una foja.

into

Comments: foja is considered the equivalent of 500 words. If the document is translated to a lesser foja, we will consider as a foja.

which makes the 2500 translators look more than a little bit foolish!

The fake websites are hosted by EuroAccess Enterprises Ltd. in The Netherlands (which is also where the email spam has been sent from). I’m not alone in receiving this type of email, further examples can be found here, and here, and here, and here, and here, and here, and even here (in Spanish).

EuroAccess have a fine ticketing system for abuse complaints… so I’m able to keep track of what they’re doing about my emails drawing their attention to the fraudsters they are hosting. I am therefore fully aware that they’ve so far marked my missives as “Priority: Low”, and nothing else is recorded to have been done… However, the tickets are still “Status: Open”, so perhaps a little publicity will encourage them to reassess their prioritisation.

He makes the argument that the Digital Theft Deterrence and Copyright Damages Improvement Act of 1999 is very much unconstitutional, in that its hefty fines for copyright infringement (misleadingly called "theft" in the title of the bill) show that the bill is effectively a criminal statute, yet for a civil crime. That's because it really focuses on punitive damages, rather than making private parties whole again. Even worse, it puts the act of enforcing the criminal statute in the hands of a private body (the RIAA) who uses it for profit motive in being able to get hefty fines.

Imagine a statute which, in the name of deterrence, provides for a $750 fine for each mile-per-hour that a driver exceeds the speed limit, with the fine escalating to $150,000 per mile over the limit if the driver knew he or she was speeding. Imagine that the fines are not publicized, and most drivers do not know they exist. Imagine that enforcement of the fines is put in the hands of a private, self-interested police force, that has no political accountability, that can pursue any defendant it chooses at its own whim, that can accept or reject payoffs in exchange for not prosecuting the tickets, and that pockets for itself all payoffs and fines. Imagine that a significant percentage of these fines were never contested, regardless of whether they had merit, because the individuals being fined have limited financial resources and little idea of whether they can prevail in front of an objective judicial body.

Another news story.

The best security program is at the business with the happiest customers.

There's a fine line between happy customers and playing piano in a bordello.

Sees a lot
Can tell the king he has no clothes
Can tell the king he really is ugly
Does not get killed by the king
Nice to have around but…how much security improvement comes from this ?

Changes happened faster that he was able to move
Did not read the signs
Good intentions went unfulfilled
A brutal way to ending a promising career
Sad to have around but…how much security improvement comes from this ?

Obviously these models of CISOs are not solving our information security problems. Instead Dr. Garigue points us to Charlemagne as a better model

King of the Franks and Holy Roman Emperor; conqueror of the Lombards and Saxons (742-814) - reunited much of Europe after the Dark Ages.

He set up other schools, opening them to peasant boys as well as nobles. Charlemagne never stopped studying. He brought an English monk, Alcuin, and other scholars to his court - encouraging the development of a standard script.

He set up money standards to encourage commerce, tried to build a Rhine-Danube canal, and urged better farming methods. He especially worked to spread education and Christianity in every class of people.

He relied on Counts, Margraves and Missi Domini to help him.

Margraves - Guard the frontier districts of the empire. Margraves retained, within their own jurisdictions, the authority of dukes in the feudal arm of the empire.

Missi Domini - Messengers of the King.

This is the way forward! Find software security champions in the architecture and development groups,help them understand the real security issues. They will find solutions you have not thought of. Same for DBAs, same for business analysts even. Its all about beating the bushes, education, and decentralizing security services. Specifically, he points out this important mandate for IT security

Knowledge of risky things is of strategic value

How to know today tomorrow’s unknown ?
How to structure information security processes in an organization so as to identify and address the NEXT categories of risks ?

To me this is our mandate and measure of effectiveness. Empower our customers, educate, and create business value. If I am a CISO  I don't want 20 people reporting to me who do firewall ruleset changes. I want one champion in 20 different groups - development teams, architects, DBAs, business analysts.

A concrete example, infosec can continue to go along with the herd and follow the "what everyone else is doing architecture" meanwhile developers are connecting every single thing in your business to the Web. I have been doing integration and new technology projects for a long time, and let me tell you - Change does not always create happy customers in the short run. But the chart below shows that information security is maybe more concerned with not causing waves rather than adapting.

The best security program is at the business with sustainable competitive advantage.

Partial Disclosure - The Good

The responsible disclosure process tends to break down in rare occasions where the vendor doesn’t want to fix the issue. When this occurs, the researcher is put into a difficult position whereby full disclosure could put users’ systems at high risk of compromise. The other case where partial disclosure becomes an alternative is when the researcher has discovered a design flaw in a protocol or underlying multiple vendor component. Examples of this case include the DNS flaws published this past summer by Dan Kaminsky and the TCP denial of service condition discovered by Robert E. Lee and Jack Louis that is currently in the disclosure process. When the flaw affects a very large number of vendors and the actual problem is located within the underlying protocols that support the communications of the Internet as a whole, one possible solution is to follow a partial disclosure model where phasing the details to the general public can be used to encourage adoption and creation of patches throughout the enormous target audience.

Partial Disclosure - The Bad

What is driving the fear surrounding partial disclosure is the potential for abuse. When a major flaw is partially disclosed, a number of potential issues may occur. First and foremost, the further along the partial disclosure path we are, the more details will be released to the public, and the higher the probability that someone (either good or bad intentioned) will figure out the exploit and disclose the details. Second, when partially disclosing, the vendor’s hand is being forced into a situation that could speed up fixes, reduce testing, and cause ripple problems elsewhere within the infrastructure. It is difficult enough to dance the fine time line when doing responsible disclosure, but if we are escalated to the point of partial disclosure, additional fuel is added to the fire.

The Ugly

The real ugly part of partial disclosure is when we add to the equation the ability to spread fear, uncertainty, and doubt into the normal user community. It is generally well accepted that FUD can be used to drive additional revenue. If it is possible to increase the perceived magnitude of the “problem” that your product or service solves, it is possible to directly impact the demand for that product or service. That is the major fear imposed by the growing trend of partial disclosure. By releasing just enough information to trigger wide scale speculation into the flaw, it is possible to create buzz and garner media attention resulting in a lot of speculation and very little hard facts around the issue. The potential for abuse by the security industry at large is enormous.

The Fix

Some have suggested a group of security researchers be convened to vet the requirement of partial disclosure and to allow for independent peer review of any security research that requires the partial disclosure process. This suggestion leaves questions regarding who would stand on this group and who would be impartial enough to ensure that the right thing was always done regardless of profit potential. It also leaves open the opportunity for member researchers to utilize the information gathered during the vetting process to position themselves to profit from the data upon release. It might be wiser to rely on a higher level authority or government entity to manage this process and use the services of security researchers as required for subject matter expertise. While a group of this type wouldn’t ensure that all partial disclosure is appropriate, it would hopefully limit the potential for abuse and the ever present chance that people try to profit from the FUD that surrounds the current partial disclosure process.

Sounds like the beginning of a joke, right?  So these two guys walk into a bar…

“The” Bruce Schneier and Marcus Ranum have an article up on TechTarget/Information Security Magazine called, creatively enough, “Bruce Schenier, Marcus Ranum debate risk management“.

Unfortunately, to get to the article, you’ll have to either already be a subscriber to IT Security, a subscriber to TechTarget, or go through the 20 minute process of signing up by giving TechTarget all sorts of “market information” about how you’re really Brandon Walsh, CSO of “The Peach Pit” Industries in Beverly Hills, CA 90210 (phone 714-867-5309).

For those of you who are already a TechTarget person, the link is above.  For those who aren’t, or those who just don’t have the time, I’ll summarize.  The “debate” is kind of awkward because both authors seem come to the same conclusion:

Risk Management, it’s something our profession should do, something humans do naturally, it’s necessary in business, but gosh - we don’t have enough data.

I’m not a cryptographer.  I don’t *nearly* have the insight on privacy and politics that Bruce has.  I’m not deep in IP communications.  I haven’t got a proven track record of innovation in IP Security products like Marcus has.  But here’s the thing, I hope you’ll never hear me pretend that I have the skill set to speak authoritatively on those subjects.  Heck, I wouldn’t claim to be a “risk” expert because I have a some insight into my shortcomings and what is needed to tackle such a complex problem.  But such a tepid article on something that (at least I think) is so important kind of, well, confuses me.

Why is it such a boring article?  I’m not sure.  Maybe because they’re just two guys who would rather debate the merits of specific controls or control activities (after all, their penetration testing debate was a huge success), but there’s no new information in the “debate”.  It’s the same old “insurance companies know risk because they have scads of data and we don’t have that” complaint. You know what?  I’m tired of hearing that line, so let’s talk about it.

HOW DO YOU KNOW WE DON’T HAVE THE AMOUNT OF DATA WE NEED TO DO RISK MANAGEMENT WELL?

Not particularly picking on Marcus, but in the article he uses the common complaint, “We lack the data to do risk management well.”  This mantra is repeated to the point where I’m blase’ about it.  But for some reason, this sentence really jumped out at me this time for two reasons.  It made me ask:

1.)  How do you know we don’t have the proper amount of data?

2.)  Can we even define “well” (i.e. what “good” risk management is) yet?

I really don’t know that the industry, especially concerning IT risk, is mature enough to really conclude that we don’t know (in the case of the former), nor that we can define (latter), conclusively.

PLAYING THE CONTRARIAN

Just because I’m feeling kind of zany this morning, let me suggest something.  Maybe there actually is lots of evidence out there for us to use.  Maybe:

1.)  It’s just that we don’t have particularly good models that provide context.

2.)  When that evidence isn’t an obvious phenomena that lends itself to easy measurement, we throw our hands up in disgust and fall back on “lack of data”, “can’t quantify risk”, “best practices work just fine” or any other number of arguments, no, excuses we use to justify our inability to be precise about the past (more or less the present or future - apologies to Niels Bohr).

IT’S IN THE WAY THAT YOU USE IT

Now I actually am happy to acknowledge that we don’t have enough data to be precise.  You, me, even smart guys like Marcus and Bruce - we’ll never be able to “engineer” risk management.  But you know what?  Neither can Insurance companies.  Sure, there are plenty of places where they have enough data to apply a traditional frequentist approach to risk valuations.   But there are plenty of times Insurers actually insure and they don’t have centuries or decades of data.  There are plenty of times when they rely on the “estimates” of subject matter experts.  There are many times they have enough information to be accurate rather than precise, and that’s good enough for them.

For that matter, it’s worth noting that there are plenty of scientific disciplines that have to deal in imprecise prior information, or evidence that’s fraught with uncertainty (what Ranum calls “squishy”, and what I’ve heard real honest to goodness physicists call “noisy”).  Unfortunately, we’re going to be like them.  Until we can read minds and predict the future, there will always be uncertainty in our measurements and posterior conclusions.  The trick is in how you deal with it and express it.  And while I really don’t know how much time Marcus or Bruce have really spent in the deep end on the subject of risk and its management - I have seen people doing brilliant things around risk (though they just aren’t mainstream).  Whether the tools are Bayesian methods, Monte Carlo engines, reductionist models of complex problems, there are risk analysts trying to deal with the problem.  These analysts are applying scientific method(s) and developing reasonable approaches to a very complex problem.  There are people trying, and our body of knowledge is growing, growing well beyond “gee, I haven’t got an obvious solution so I’ll blame it on lack of data”.  Heck, I’ve seen readers of this blog suggest Douglas Hubbard’s book in other security forums!*

I’VE GOT YOUR DATA RIGHT HERE…

But we don’t have enough data?  I have to ask, how much more do we need?  I mean crikey, JPMC just visited our ISSA chapter claiming, like, a bajillion events an hour.  There’s not one, but several companies out there that will want to tell you about how they have deep “insight” into the attacker community.  The boundaries of IT Risk losses are pretty well established by events that happen to public companies.  We have pretty mature testing/assessment tools and methodologies now that help us test our ability to resist the force an attacker can apply to us.  So what part of the Threat Landscape, Asset (Controls) Landscape, or Loss Magnitude landscape is too incomplete (and what are you doing to find the information you need)?

SO WHY DO WE FAIL?

Which brings me to a final, somewhat depressing conclusion.  Maybe there’s data, and maybe we’re starting to see the means to use it.  But in the end I do have to agree with Marcus that the vast majority of the infosec world *is* doing a really, really bad job with regards to “risk” and “risk management”.  The majority of people I know consider GRC to be a cruel, expensive joke.  Risk Assessment Methodologies tend to be built on the faulty premise that if we create a repeatable process, our measurements and conclusions will magically become accurate and wise.  Risk models tend to be factors loosely measured by ordinal scales and then somehow “multiplied” together to create a relatively meaningless qualitative value.  The State of the Union here is not good.  But after reading such a superficial treatment of an important and complex subject, I am left wondering if Bruce and Marcus were the right people to write about risk management in a mainstream publication.  As Inspector Callahan says, “A man’s got to know his limitations.”

===============================

* Speaking of which, if you want to do one cost effective thing to address your uncertainty - go find Douglas Hubbard’s book. It’s even got a nice recommendation from Peter Tippett.  The book is called “How To Measure Anything” - the title sounds rather hyperbolic, but there are good techniques in it we can use to identify useful information and refine our ability to frame that qualitative information into quantitative values. The key is how Hubbard has you deal with your uncertainty.  For those of you who are more scientific minded and want to dig deep into the subject, I have on good authority that E.T. Jaynes “Probability Theory, The Logic of Science” is a rather under appreciated work.