Experts say the precipitous drop-off in spam comes from Internet providers unplugging McColo Corp., a hosting provider in Northern California that was the home base for machines responsible for coordinating the sending of roughly 75 percent of all spam each day.

Certainly this won't last:

Bhandari said he expects the spam volume to recover to normal levels in about a week, as the spam operations that were previously hosted at McColo move to a new home.

"We're seeing a slow recovery," Bhandari. "We fully expect this to recover completely, and to go into the highest ever spam period during the upcoming holiday season."

But with all the talk of massive botnets sending spam, it's interesting that most of it still comes from hosting services. You'd think this would make the job of detecting spam a lot easier.

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.

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.

We have been conducting polls of our customers and of IT professionals at technology trade shows for the past two years and the results are in: Pulling together all of the management pieces and processes is even more crucial in a virtualized environment.

So what does this mean for you? You will need to refine your incident and problem management processes with new technologies in order to reduce downtime and maintain end user performance. But of course even the most basic technologies are not well integrated even in today’s world.

I recently participated in a Gartner Conference and watched to my amazement a real-time electronic survey of the audience. To my disbelief, the audience, filled with 300+ people from Fortune 2000 companies provided real-time responses to the question:

What level of integration does your IT org have between event management and service desk applications?

• None: 10%
• Manual Phone call from IT ops to IT service desk staff member: 46%
• Manual click button on event manager to open trouble ticket: 20%
• Automated event management system automatically opens trouble ticket without requiring human oversight or approval: 24%

Unbelievable… still very few of the survey respondents have yet to formalize problem management systems with event management systems. For 56% of the audience the process is still manual!

Another interesting real-time survey question at the Gartner Conference was:

Who in your organization is responsible for critical problem processes and resolution?

• IT Service Desk 13%
• IT Operations 49%
• Process Team 12%
• Other 9%
• Responsibility not formalized 17%

Virtualization adoption and the speed with which things change in a virtualized environment require automation and will transform Incident and Problem Management. Clearly with this new technology we are required to re-think Organizational, Behavioral and Cultural Challenges required to take advantage of the opportunities that virtualization provides.

Incident and problem management processes and metrics must bridge organizational silos that have been the norm within IT. With virtualization, people have to work more closely together in the different silos than ever before. IT leaders need to break down the walls between the technology-centric silo mentalities.

Business Imperative Action Plan:

1. What can you do today? –Understand the impact of virtualization on incident and problem mgt. workload, provide technology training for helpdesk/service desk staff.
2. What can you do in the next 12 months?

Formalize problem management processes, metrics and personnel.
Invest in tools and processes for systems on virtualized servers.
Long term: On the Radar Screen!
Instill teamwork into all groups responsible for the virtualized environment service and support. Map components and configuration items directly to end user services.

Final Thoughts: Know the management pieces and ensure that they fit together. It’s great to buy new technology, but be demanding to ensure that your vendors show you have they will help to link all these pieces together - Change, Inventory, Incident, Problem, Server, Capacity, Performance, Configuration, Event, and Integrated Workflow.