Lots being written about the Cloud, most of it quite dark and gloomy.  In fact I’m surprised, that Hoff hasn’t got a preso spooled up called “The Toxic Cloud” or something similarly ominous for his next speaking tour.
That said, the Economist does a great job distilling the issue into a simple statement -

Cloud computing is a trade-off between sovereignty and efficiency.

Let me ask you -  if you had to put your money on one of those horses, considering your average profit-preoccupied business, which would it be?  I’d put my bottom dollar on the thoroughbred named “Cost Center Reduction”, to place.

WHO ARE WE TO STAND IN THE WAY OF “PROGRESS”?

I’m always fond of Jack’s rule that the role of information risk management boils down to three deceptively simple premises:

• Reduce Risk.
• Reduce Loss.
• Create Operational Efficiencies.

So it would seem antithetical to the charter of the Chief Security Officer to stand in the way of progress as embodied by “cloud computing” (not to mention dangerous to long-term job security).  And I think that this presents opportunities to discuss strategies for managing risk, strategies that aren’t too theoretical and have practical application (though actual “cloud” use by enterprises may be rare at this point).

ON RISK REDUCTION IN THE CLOUD (or, How To Learn From the Shortcomings of PCI DSS)

The good news is, there’s already a well-established model for managing the risk around outsourcing the processing of “confidential” information.  The bad news is, that model kinda sucks it.

The Payment Card Industry, known as the “PCI” or “meal ticket” to many in the industry, faced a similar problem with the introduction of GLBA.  As I see it (and I’m not at all close to the PCI, at all, so this is all just abstract soliloquy) the PCI had one of two choices when faced with the prospect of other people managing their sensitive information:

1. Accept the *massive* amount of GLBA risk their business creates and spend a TON of money to build out the infrastructure (both process and IT) to manage the consumer data themselves (in conjunction with the banks, of course) and never have it grace the computing systems of the retailer.  Or,
2. Transfer the GLBA risk down to the retailer and have them bear the majority of the risk (and cost of reducing risk to a level that might be tolerable to the US Government).

(Martin, you may recall our Twittering about PCI a while back.  This is the crux of my view on the subj.)

Now fortunately, the CSO’s of the world are going to be a little more “invested” in protecting the information they are stewards over, and unlike the PCI, will remain primarily responsible for the C, I, & A of the data in the Cloud.  The cool thing is, this actually presents a great opportunity to start building a meaningful model for co-management of risk!  In fact, we can take the PCI model of contractual risk transference but modify where it goes all wrong, and start working to create something better.  And we can start by euthanizing some faulty assumptions.

JUST HOW INFORMATIVE IS PCI DSS?

What might be the.greatest.mistake of the standards compliance mentality is the assumption of value for the past-state measurement.  That is, I believe that the CSO needs more than some “past-state” assurance in order to understand their risk.    If you look at the concept of “PCI compliance” it really is an examination of a past state of nature that is assumed to be relevant to current and future states.   Many people (myself included) are not at all convinced that this past-state is nearly as informative as those who mandate it’s measurement believe it to be.

That’s not to condemn past-state measurements as completely non-informative,  they most certainly are useful.  It’s just that no self-respecting CSO sleeps well because they were deemed “PCI compliant” 10 months ago.  They sleep well because they have good visibility into current-state information and confidence in their strategy concerning future-state (based on that visibility and the outcomes of sound IRM models).

MOVING PAST THE VULNERABILITY SCANNER INTO INTELLIGENCE AND WISDOM

So realizing this new importance (to me, at least) concerning visibility and IRM models, I’m lead to the conclusion that if we are to manage risk in the Cloud, we’ll have to move beyond “PCI Compliance” or the concept that some regular “audit” of controls in place at the host is all we need to understand our ability to manage risk.  No, the CSO must have good information concerning current and probable future states.   This is that “visibility” I spoke of above.  In fact, we’ll need significant amounts of piercing, transparent visibility.  And in order to gain that visibility, our insight into Cloud Risk Management must include significant provisions for understanding a joint ability to Prevent/Detect/Respond as well as provisions for managing the risk that one of the participants won’t provide that visibility or ability via SLA’s and penalties . These SLA’s must be expressed in measurable terms (more visibility), and those metrics must have their roots in the things that help understand how we manage risk (those aforementioned IRM models).

THE CLOUD COMPUTING SECURITY SILVER LINING (sorry couldn’t resist)

As I mentioned earlier, I do see an opportunity to create insight.  The need for visibility and IRM models would allow us to create a “guidance” if you’ll allow me to use the term.  Not a standard or a “best practice” to audit by, but simply a reference document that says “if you’re going to put information on somebody else’s systems and still hold some significant responsibility for that information, here’s the considerations, why they are considerations, and how you might go about collaborating on the management of risk”.

And I think that if we undertake this journey, there is going to be a lot of growth and risk management innovation along the way.  But keen insights into what it means to manage risk will be necessary, and secure and forthright collaboration will be of absolute importance.

I say that last bit because, if these pundits are right about the utility of a hosted computing model - the Cloud will happen regardless of the CSO’s ability or desire to manage it.

Blogger: Dan Blum

With the crisis in financial markets still unfolding, it is important to draw what lessons we can from the experience. Since the roots of the crisis lie in a monumental failure of risk management, it’s important to understand more about what happened, and then draw some parallels to our business risk management and  IT risk management situations.

The risk management failure in the housing market and on Wall Street had multiple interdependent dimensions:

• Mortgage lenders abandoned long standing prudent loan practices. They made too many loans that buyers might not be able to repay. Exotic instruments like ARMs, option ARMs, and interest only loans proliferated. In many cases, all pretense of lending standards were abandoned, so-called “liar loans” approved.
• Capital was grossly over-leveraged. Mortgage lenders and other financial services packaged loans into securities, which they sold to raise capital to support more lending. Real capital reserve requirements to back loans were reduced. Of course, if borrowers could not repay loans, all or parts of the derivative securities would become worthless.
• Risk was aggregated at Fannie Mae, Freddie Mac, and mortgage loan insurance companies. These companies bought or insured some mortgage loans, providing something of a backstop should loans fail. Government sponsored enterprises (GSEs) Fannie and Freddie in turn became over-leveraged and securities that they sold were in turn repackaged in the murky brew of mortgage-backed securities called collateralized debt obligations (CDOs) and other exotic instruments returning generous yields.
• Non-Caveat Emptor. Institutional wealth funds and financial services firms who should have known better bought securities that had been deliberately structured to obfuscate risk. They bought securities they didn’t understand with buried tranches of toxic subprime loans..

It was a great Ponzi scheme – one that kept working as long as housing prices were going up; the recipients of subprime loans could always flip that house to the next buyer. Everyone made money. As Chuck Prince of Citigroup famously put it during a July, 2007 interview: “So long as the music is playing, you’ve got to keep dancing. We’re still dancing.” But one month later, the music stopped. Since then, Citigroup and other financial institutions have taken massive writeoffs with more to come. Wall Street titans like Bear Sterns, Lehman Brothers, Merrill Lynch, and AIG have fallen or been bought out.

What can we learn from this risk management debacle?

As business risk managers and investors, we should ask questions like these:

• Does the executive incentive structure of the company encourage managers to dance around risk? Many Wall Street firms paid senior managers 5 times their salary in bonuses tied to annual growth alone.
• Is the company over-leveraged? Is it borrowing too much money and betting it on ventures with uncertain outcomes?
• Are financial models used for risk management realistic? Earlier, I described the mortgage market of the past few years as a Ponzi scheme, where risk management models must have assumed prices would keep rising. Unlike the dotcom boom whose demise many predicted, very few in the industry foresaw the sharp declines to come in housing prices and sales volumes. Historically, the U.S. housing market has been a steadily rising one, but on the other hand the 2000s saw unprecedented rates of price increases. In reality, what goes up must come down.
• Has your company’s risk council ever performed worst case scenario analysis and built adequate reserves? In the days before economics emerged as a would-be “hard” deterministic science, business leaders may have been more cautious, more aware of and more accepting of uncertainty. Events like the Great Tulip Bubble came once in decades or centuries – not every few years. Note that legendary investor George Soros has proposed a Theory of Reflexivity that, if true, helps explain the recent extremes of boom and bust cycles. This theory holds that market participants model market behaviors based on self-interest, and for a time, their manipulations change the reality of the market – until gravitational forces bring it back to earth. Has the music of ephemeral success played to the backbeat of deterministic-sounding economic models gone to your heads and infected your risk management models?
• Are cost cutting efforts pursued blindly? Outsourcing and other forays into treacherous global waters may be giving away the crown jewels. Smart companies cut costs, but they do it in smart ways. Smart companies think like intelligence agencies as they parcel out work to different partners with varying levels of dependability, and they check on those partners.

Risk management failures can also occur at the more technical level of IT security. As IT risk managers, we might ask questions like these:

• Are the accounting and financial systems your IT department supports under adequate control? As Fred Cohen wrote in one of our documents: “Many companies use computers to manage financial systems, and despite the Sarbanes-Oxley Act (SOX) claims about accounts being properly kept, there are many attacks on financial systems that remain. For example, most of the largest financial systems in the world running on common financial databases do not use double-entry bookkeeping and are thus susceptible to all manner of frauds by insiders.” We find it troubling that a prudent control dating back to the 12th century is going out of style in the name of convenience and cost cutting. Kind of like credit checking became anachronistic during the housing bubble, eh?
• Is the “separation” in your “separation of duty” (SoD) for real? Sure the SOX auditors are looking for SoD, and maybe you have different administrators with different accounts maintaining different systems or functions. But when they say Western civilization may be but one weak password from collapse they’re not lying. Look what happened to Sarah Palin’s email account! Weak and straggly SoD is a problem across all critical IT systems where deperimiterization and server consolidation may be bringing down protective barriers, identity management is weak, and strong process controls (e.g., where two people must sign on, one perform a critical operation such as backbone router reconfiguration, and the second observe) abandoned in the name of expediency.
• Are risks being aggregated to unacceptable levels in centralized control systems? There are many ways that risks aggregate within enterprise IT infrastructures as we pursue automation and cost cutting. Network risks aggregate when centralized domain name system control is implemented. Application risks aggregate when common infrastructure is shared among applications. And enterprises aggregate platform risks when they use low-assurance endpoints, authentication, and directory systems with single sign-on to access large numbers of resources and don’t separate high consequence systems.
• Non-caveat emptor: Has IT security really done the worst case consequence analysis, attack graphs, and vulnerability analysis to know when putting more eggs in a supposedly stronger basket aggregates risks to an unacceptable level? Or are you depending only on vendor claims about some black box appliance equivalent of a risk-obfuscated CDO security? Caveat emptor (buyer beware) again! (The good news is we’ll keep talking about promoting vendor and product rating systems so you don’t have to do all the detailed product analysis yourself, but that’s another post.)

There are many parallels between the monumental risk management failure in the financial markets, and the probable weaknesses in our day to day business risk management and IT risk management. Abandonment of prudent practices for profit; excessive leverage and centralization; ill-constructed risk analysis models; risk obfuscation; and a failure of caveat emptor seem to be common problems. Please take this as a wakeup call to sharpen up the risk management thinking, process, and execution.

I arrived in Austin Sunday night to get ready for a factory tour on Monday, a kickoff dinner and then two days of briefings from Dell executives, including Michael Dell himself! Dell’s ISG business is growing at a very fast pace and continues to build momentum and focus within the broader organization.

We had a nice overview of the product roadmap, including some of the exciting enhancements Dell is making to their storage products such as the MD3000 and the new EqualLogic PS5000 series iSCSI solutions.

I really enjoyed the Council meeting and it reminds me all over again; what I admire about Dell is the way they and Michael Dell himself stay close to the customer. The entire purpose of this event is to “get it right” and determine meaningful ways to embrace change (including change in the manufacturing process) in order to make their customers more successful. Ah shucks, you may say that all companies behave this way… well I must tell you that is not true and at times, I find it difficult as we continue to grow to stay as close as I would like to all of our customers varying needs and directions.

This concept of gathering, internalizing and embracing customer feedback is a simple principle of Business Success stories. Always trying to improve the pace of change and build meaningful sticky relationships with customers. Dell’s very successful Ideastorm site where customers post product feedback and are active participants in the Dell community is a great example of how to do this right. No other hardware vendor that we have worked with or attempted to work with has ever gone to the extent of embracing change that Dell has during our 5-year relationship.

From the custom factory integration services to the attention to detail in the order and manufacturing, and logistics processes, Dell helps us execute for our customers and I must admit that we could not have built the business as quickly or efficiently without Dell!

So thank you Michael Dell for building a business that embraces change and is focused on helping your ISG customers succeed.

"consumers hate tokens."

"Everyone wants to be the single federation platform for everyone else."

"Federation will never work. It won’t work because the single most important consumer Web applications in the world are scared of it. Banks hate the concept because it becomes a weakest link in the chain problem."

"Tokens don’t actually solve most security problems, like man-in-the-middle, phishing, and keystroke-logging malware."

"Oh yes, and finally, consumers are going to have to carry around 13 of them just to make sure they can log into whatever they need to log into since no one will federate."

"Global federation is nowhere near a solid concept in the consumer space, despite what the vendors will try to sell you."

"This is a long term problem. If you work on it and make any progress against it, you'll find yourself much smarter at the far end, than you were at the near end.

When I was in Norway about 5 years ago, I was there very close to the summer solstice. I was wandering around town at 2 o'clock in the morning and there was plenty of light out. You come to a sign that says New Minsk about 60 km and it points south.

And I ask the lady "what country is this?"

She scratched her head for a bit, and said "well I think its Norway"

I said "well who plows the roads?"

"well Norway does, but he have to pay them."

There is a triple boundary in this town that I was in between Norway, Finland and Russia.

But what I did there, was, I had a card about wallet size, I stuck it into a machine, I punched in four digits, and it gave me about 2,000 krone, whatever the hell that is.

Now there are a lot of participants in that transaction. When I put a card into that machine, punch in a pin, and it gurgles for awhile, and finally gives me, a fairly large amount of money. There are a lot of participants in that transaction. The bank that owned the machine that gave me the money, it gave some money away -- that bank wants it back. The pin is necessary to convince my own bank that I'm me. But I don't want my pin to be broadcast all over the world. My bank in the us, it hasn't really given out or taken in any money, really. But there is a lot of credits involved here. Somebody needs to charge somebody else for having more money available. Even though there was actually no cash transfer.

And the problem that I have in mind is
- who are all the participants in an ATM transaction?
- what do those participants need to satisfy their problems?
- how is that in fact done?

In a general way, does the atm system actually work in some reasonable sense? To which the answer is by the way: yes. The atm system damn well works. With extremely high reliability and accuracy. It surprises me. Its quite a bit different than voting machines.