Richard Stallman - the man that gave us GNU - doesn’t trust Cloud providers with his data and says you shouldn’t either.  Richard believes we should store our private data on our own computers using ‘free’ (as in freedom) software.  The ironic part for Richard is that a significant portion of the Cloud is powered by open source software which he indirectly created (think gcc).

Richard sees it as a question of control.  Control is important but it isn’t the only variable.  Rather, I see it as a question of control, competence and economics.

The quick rebuttal to Richards’ view is this: the average computer user is not as smart as you.  Control is not the same as competence.  Control is about exercising choice, not about requiring everyone in the world to develop sufficient skills to protect complex hardware and software systems (aka their computer) against ever increasing threats.

My view is that privacy is not ‘free’.  It comes at a cost.  Whether you run your own systems or rely on someone else to do it, there is a cost.  There is cost in designing and implementing mechanisms to support privacy.  Beyond upfront costs there are ongoing expenditures to ensure privacy is maintained e.g. maintaining access control lists, testing and applying security patches, data leakage prevention etc.  None of these things are ‘free’.

If we agree that privacy costs money then how much is your privacy worth?

Stop for a second - think of a number…  

Now did we all think of the same number?

The problem with a one size fits all approach to privacy is that we each place a different value on it.

Checking in on the EPIC site, I saw this:  

A new report from Pew Internet and American Life Project indicates that “cloud computing” applications, such as web-based email and other web apps, are raising new privacy concerns. The report Use of Cloud Computing: Applications and Services found that 69% of online Americans use webmail services, store data online, or use software programs such as word processing applications whose functionality is located on the web. At the same time, “users report high levels of concern when presented with scenarios in which companies may put their data to uses of which they may not be aware.” For example, 90% of respondents said that they “would be very concerned if the company at which their data were stored sold it to another party,” 80% say “they would be very concerned if companies used their photos or other data in marketing campaigns,” and 68% of “users of at least one of the six cloud applications say they would be very concerned if companies who provided these services analyzed their information and then displayed ads to them based on their actions.”

What does that tell us?

The average (American) Internet user finds Cloud services convenient but has concerns about how their privacy might be affected by Cloud providers actions (duh!).  The survey identifies a lack of awareness in how private data is used in some consumer based Cloud services (consistent with web advertising awareness surveys).  

Unfortunately, the results of this survey are not very actionable.  The survey doesn’t mention whether these are all ‘free’ Cloud services (we can only assume they are) or ask the respondents what their expectations of privacy are and how much they would be willing to pay for different privacy assurance levels. 

On a sidenote, respondents were not asked if they had actually read the privacy agreement for the services they signed up to.  But the providers know if they did or not…  Or at least, they have the data to figure it out.  At sign up time they can measure the time between displaying the privacy agreement and the user clicking ‘I accept’.  If its just a few seconds then its pretty obvious there was more scrolling than reading going on.  But I think we can probably guess the answer without the data ;-).

I believe we need to be able to link expectation of privacy with cost.

• How much are you willing to pay for privacy?  What level of privacy assurance do you need?
• How much is your Cloud Provider paying to protect your privacy today?  What privacy services could they reasonably offer if they had customers willing to pay?  How might this compare with how you manage your private data on your home computer today?

The cynical view is that we expect privacy but don’t want to pay for it.  Its a bit like uptime - there is a parallel universe out there, where internal IT departments allegedly meet their 99.999% uptime SLAs, but when Gmail goes down, the Sergey Brin witchcraft dolls come out.

From a provider perspective, the “cost” of privacy invariably gets bundled under that line item called ‘Information Security’.  And don’t be fooled, the cost of privacy in reality is more than the salary of the person employed to be the privacy advocate (if there is one).  If we can’t see how much our providers are spending on our privacy then how can we judge if they are spending enough?  And what is enough?  And what can I get if I’m willing to pay a little extra?

Personally, I would rather we get some transparency around privacy costs and assessment of offerings.  However, without a sufficiently sized market of customers willing to pay for privacy assurance and Cloud Providers willing to be more open, I won’t hold my breath.

What about you?  Would you be prepared to pay for privacy?  Should providers be more transparent about what they do and don’t do and how they do it?
 
 

Apparently a fellow recently was indicted on charges of hacking into the Republican vice presidential nominee's Yahoo email account, by simply doing some research on the Internet to find her birthday, zip code, and the answer to her security question, "Where did you meet your spouse?" All told the attack reportedly took under an hour to complete.

Given the level of interest in Palin and other public figures, and the large amount of information about them available to the public, it makes sense that they will be some of the easiest targets for attacks like this.

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?

California — Our Governator passed a law making it illegal to secretly scan RFID tags

He then killed a bill that would limit the amount of time retailers could hold onto customer information, for the second year in a row.

Nevada — A new law requires businesses to encrypt customer information sent outside “the secure system of the business” except by fax

Massachusetts — New rules require that organizations that store personal data about its residents must encrypt the data on portable devices starting in 2009.

Brian Krebs at the Washington Post has the nitty gritty about the above new laws.