This makes the compliance area rife for scammers, who send letters or emails claiming that businesses owe them penalties or haven’t filed the right forms.

Tony Mancuso at Nolo, the publisher of books about corporate forms and law, writes about how to recognize some of these scams.

One official-looking legal letter came into the controller’s office recently. It was from an “agency” calling itself the Corporate Minutes Compliance Counsel, or somesuch, and it strongly advised (warned, really) that Nolo send the Board a payment of $125 to prepare its state-mandated domestic corporation statement. Failure to do so could result in dire consequences, the letter advised, including a loss of corporate status with the Secretary of State.
Nolo’s controller, who has years of experience with real and bogus corporate service solicitations, shredded this letter immediately.

This scam also seems particularly nasty because not only can the scammers steal money from you, they will get valuable information and insight into your private business!

One smart way to avoid these scams is to check anything suspicious–call your secretary of state office or look up the organization who sends you that nasty letter. Or learn more by reading the full article here.

HANSEI - WHAT IS “RELENTLESS REFLECTION?” - And why we’re talking about it in the context of Risk Analysis.

Recall from yesterday’s post about how I got to thinking about the concept of Hansei-Kaizen, “relentless reflection” and “continuous improvement” and how we might apply that to risk management.  It’s a concept born of Toyota and is, in some way, the foundation for “Lean” production.

Call me biased, but I think that Hansei - the act of ‘relentless reflection’ made structured is the analytical function.  And I hate to debate (post-mortem) the father of Toyota quality success when he says that Hansei is the “check” in Plan/Do/Check/Act, but I think that Hansei also applies to the “Plan” of the P/D/C/A or Deming cycle.

You’ll recall the P/D/C/A cycle can be thought of even as an implementation of Scientific Method, in that it is Observation & Hypothesis Creation (P), Experiment (D), Analysis (Check), and Act (Revise/New Hypothesis, etc…).  Well then as such, the Hypothesis creation involves creating a model or creating an expected outcome for data using the currently accepted model.

So in our industry there is an opportunity for Relentless Reflection in both the Observation and Hypothesis (Plan) creation steps, and the Check step.  We create an estimate for control strength, or probable losses in the context of risk- then we go to Experiment step.  That hypothesis can be put it into production, have an audit, have a penetration test, whatever, in the context of the Do step.  BTW - using Hansei/Analytics in Plan is one way that strong analytical functions can really make penetration testing more useful - as a means to test the estimates and inputs into a model.  It’s Penetration Testing 2.0!  (<- tongue fully in cheek, yes)

Those who are versed in the reasons to merge Six Sigma and Lean together are probably already seeing where I’m going with this today.  But before you think that a simple DMAIC function is all that is needed to create proper “Hansei”, let me encourage you to keep reading.

Now if the analytical function can said to be “reflection”, why must it be relentless?

One word.  Change. There are essentially four separate “landscapes” or sources of change that we face (more on those tomorrow).  But anyone who has tried to manage system compliance, log management or policy exceptions knows that change is possibly the most difficult thing we security professionals must manage.  And when you think about it, there aren’t too many other business functions like information security where significant visibility and insight about the environment is needed for “complete” information (get bullish on Log Management is my recommendation).

HANSEI STEPS ADAPTED TO INFORMATION SECURITY

This is one of those quality control concepts that we can mangle adopt.  At Toyota, Hansei-Kaizen includes the following basic steps:

1. Initial problem perception
2. Clarify the problem
3. Locate area/point of cause
4. Investigate root cause (using an ask why 5 times approach)
5. Countermeasure
6. Evaluate
7. Standardize

Now it’s important to note that part of this includes the concept of Go See For Yourself, called “Gemba“.  Gemba can be translated as “the actual place” or “the place where virtue or truth is found.” At Toyota this might mean going to the shop floor to see the issue at hand in the production line.  But for us, that’s a problem because we live in the virtual world.  There’s usually not much use in hanging out in the wiring closets to try to see the problems.

But if you combine the concept of Gemba with the concept of “Nemawashi” –the process of discussing problems and potential solutions with all those affected- we can forge a similar concept using risk analysis.  That is discussing the issue and the risk associated with an issue (what some people would call “risk management”) with the business/LOB/data owner and let them accept authority and the risk decision.  We, the risk analyst, our goal is simply to perform items 1-5 (presenting countermeasure options that include transferring or accepting risk).  By going to the line of business and involving them, responsibility is shared.  Also, if you structure organizational behavior right, personal risk is transferred!

This sort of approach is also in harmony with concepts like “mutual ownership of problems,” or “genchi genbutsu,” (solving problems at the source instead of behind desks), and the “kaizen mind,” (an unending sense of crisis behind the company’s constant drive to improve).

One of the criticisms I have with the way most people try to implement DMAIC into “Lean”

REQUIREMENTS

Now to get this done, I really see three significant requirements.

1.)  A change in political structure.

2.)  Models that provide consistent, defensible analysis.

3.)  A Quantitative approach.  This means using actual units of measurement (not just amorphous percents, ordinal scales, etc.)  for risk and it’s subsequent factors.  Sure there are times when Q&D qualitative approaches are acceptable, but policy should be to have quantitative analysis whenever and wherever possible.

That last item - the quantitative approach - is really quite important.  And the reasons why will be discussed further in tomorrow’s post:

“What should we be reflecting about? & What is needed for reflection?”

P.S.  Your comments and suggestions, as always, are welcome.

P.P.S  Those who may be familiar with Lean/SixSigma/Kaizen sorts of mashups may be thinking - “hey, an Analytical step is built into SixSigma”.  Well, yes there is some prevision for analytical functions based on statistics, but I find SixSigma geared towards creating a State of Knowledge about operational processes, not towards creating a State of Wisdom for CISO’s around security & risks “big questions”.  In otherwords, the analytical function in DMAIC is in the context of Kaizen, and a different step than “reflective” analytics.

Doesn’t this seem backwards to you? Shouldn’t the MBTA be suing the vendor who sold them the flawed system? Security problems go away by mandating independant security testing before a product is accepted, not by trying to get security researchers to be quiet. This is a good example of how the reactive approach doesn’t work. The flaws are still in the system and suing researchers has just shined a bright light on them.

Update 08/09/2008 6:00pm EST:

The EFF is appealing the injunction which is blocking the students from speaking about the results of their testing.

A telling quote from Kurt Opsahl, staff attorney at the EFF gets to the heart of the issue:

“Courts have found that the First Amendment covers these things. We believe that this is a protected speech activity. When you discuss security issues, if you are telling the truth, that is something that should be protected.”

Apparently the MBTA has known about this problem since at least March, 2008 when a graduate student from the University of Virginia announced he was able to break the encryption system.

The U of VA researcher gave an interview where he described why security by obscurity is not a valid security approach for a cryptosystem:

Q: What are your thoughts on security by obscurity? Is NXP using this method of protection?

A: Security-through-obscurity hardly ever works. The lack of proper peer-review often even hurts the security of the system. Our Mifare work discovered several vulnerabilities that could be fixed without increasing the cost of the cards. NXP did for a long time rely on obscurity for the security of some of their products, but now decided against this outdated design approach and instead bases the security of newer RFID cards on publicly scrutinized cryptography and independent evaluations.

Q: Can you explain “Kerckhoffs Principle” and why it applies to your work?

A: Kerchoff, who lived in the 19th century, observed that keeping anything secret is really hard. So instead of relying on the secrecy of your whole system, it would a lot easier to only rely on the secrecy of a small secret key. Security systems should hence be publicly known and analyzed, and only the key should be secret. When properly realised for RFID cards, Kerchoff’s principle means that by analyzing their own cards, thieves cannot compromise your cards. This is contrary to our Mifare work, where we only analyzed a few copies of the the secret algorithm that is found in all cards and were consequently able affect the security of all the other billion cards out there.

The MBTA not only accepted a security system which relied on security by obscurity but once accepting this flawed model must try to maintain this obscurity with the court system.

The documents detailing the presentation are here.

The towers are gone now, reduced to bloody rubble, along with all hopes for Peace in Our Time, in the United States or any other country. Make no mistake about it: We are At War now -- with somebody -- and we will stay At War with that mysterious Enemy for the rest of our lives. 

It will be a Religious War, a sort of Christian Jihad, fueled by religious hatred and led by merciless fanatics on both sides. It will be guerilla warfare on a global scale, with no front lines and no identifiable enemy. Osama bin Laden may be a primitive "figurehead" -- or even dead, for all we know -- but whoever put those All-American jet planes loaded with All-American fuel into the Twin Towers and the Pentagon did it with chilling precision and accuracy. The second one was a dead-on bullseye. Straight into the middle of the skyscraper. 

Nothing -- even George Bush's $350 billion "Star Wars" missile defense system -- could have prevented Tuesday's attack, and it cost next to nothing to pull off. Fewer than 20 unarmed Suicide soldiers from some apparently primitive country somewhere on the other side of the world took out the World Trade Center and half the Pentagon with three quick and costless strikes on one day. The efficiency of it was terrifying. 

We are going to punish somebody for this attack, but just who or what will be blown to smithereens for it is hard to say. Maybe Afghanistan, maybe Pakistan or Iraq, or possibly all three at once. Who knows? Not even the Generals in what remains of the Pentagon or the New York papers calling for WAR seem to know who did it or where to look for them. 

This is going to be a very expensive war, and Victory is not guaranteed -- for anyone, and certainly not for anyone as baffled as George W. Bush. All he knows is that his father started the war a long time ago, and that he, the goofy child-President, has been chosen by Fate and the global Oil industry to finish it Now. He will declare a National Security Emergency and clamp down Hard on Everybody, no matter where they live or why. If the guilty won't hold up their hands and confess, he and the Generals will ferret them out by force. 

Good luck. He is in for a profoundly difficult job -- armed as he is with no credible Military Intelligence, no witnesses and only the ghost of Bin Laden to blame for the tragedy.

One unintended lesson I take away from Hunter's life is how important patience is. Obama is a politician and may yet disappoint us all, but I gotta believe Hunter would be seriously impressed. If he had waited another couple of years, he may have seen a lot of the stuff he fought for in 1968 and 72 come to fruition. Sometimes you are just 36-40 years ahead of your time and you have to be ok with that and figure out how to deal if possible. (Note - it sure sometimes feels this way in software security). Speaking of security:

Security 

by Hunter S. Thompson (1955). 

Security ... what does this word mean in relation to life as we know it today? For the most part, it means safety and freedom from worry. It is said to be the end that all men strive for; but is security a utopian goal or is it another word for rut? 

Let us visualize the secure man; and by this term, I mean a man who has settled for financial and personal security for his goal in life. In general, he is a man who has pushed ambition and initiative aside and settled down, so to speak, in a boring, but safe and comfortable rut for the rest of his life. His future is but an extension of his present, and he accepts it as such with a complacent shrug of his shoulders. His ideas and ideals are those of society in general and he is accepted as a respectable, but average and prosaic man. But is he a man? has he any self-respect or pride in himself? How could he, when he has risked nothing and gained nothing? What does he think when he sees his youthful dreams of adventure, accomplishment, travel and romance buried under the cloak of conformity? How does he feel when he realizes that he has barely tasted the meal of life; when he sees the prison he has made for himself in pursuit of the almighty dollar? If he thinks this is all well and good, fine, but think of the tragedy of a man who has sacrificed his freedom on the altar of security, and wishes he could turn back the hands of time. A man is to be pitied who lacked the courage to accept the challenge of freedom and depart from the cushion of security and see life as it is instead of living it second-hand. Life has by-passed this man and he has watched from a secure place, afraid to seek anything better What has he done except to sit and wait for the tomorrow which never comes? 

Turn back the pages of history and see the men who have shaped the destiny of the world. Security was never theirs, but they lived rather than existed. Where would the world be if all men had sought security and not taken risks or gambled with their lives on the chance that, if they won, life would be different and richer? It is from the bystanders (who are in the vast majority) that we receive the propaganda that life is not worth living, that life is drudgery, that the ambitions of youth must he laid aside for a life which is but a painful wait for death. These are the ones who squeeze what excitement they can from life out of the imaginations and experiences of others through books and movies. These are the insignificant and forgotten men who preach conformity because it is all they know. These are the men who dream at night of what could have been, but who wake at dawn to take their places at the now-familiar rut and to merely exist through another day. For them, the romance of life is long dead and they are forced to go through the years on a treadmill, cursing their existence, yet afraid to die because of the unknown which faces them after death. They lacked the only true courage: the kind which enables men to face the unknown regardless of the consequences. 

As an afterthought, it seems hardly proper to write of life without once mentioning happiness; so we shall let the reader answer this question for himself: who is the happier man, he who has braved the storm of life and lived or he who has stayed securely on shore and merely existed?

A ship is safest at port, but thats not why we build ships.