I’d love to have another blog even more specific - “Ok, that Assurance is Evidence Of What, Exactly?

Today he has a great article called:

What’s the matter with Risk Management?

And “in short, it’s everything.” It pretty much sums up why I had to grow to re-evaluate how our industry does risk, risk management, approaches controls & vulnerability and find a new way.   A couple of things jump out at me in reading Chris’ article:

1.)  Just because that Deming cycle sucks and is full of unknowns doesn’t mean “risk” doesn’t exist, nor that it isn’t of primary importance. Nor does it mean that in the absence of model & methodology, we won’t be “doing” risk analysis anyway - just in an ad hoc method and completely from “the gut”.

Our industry calls these unstructured risk analysis “Best Practices”, as it’s an easy and convenient way of sweeping the unknowns under the rug of bureaucracy and enforcing it via peer pressure.

2.)  What this “suckiness” does mean is that your model and methodology aren’t helping you. As Chris intimates, there is too much uncertainty in the inputs for his model (they are, in the language of Bayesians - too subjective to be useful priors).

Take for example how we might be approaching the “controls” part of our analysis.  Chris writes:

“2. What are the controls that we have to employ?
800-53, ISO 27001, PCI, etc.

Still kinda good, but we basically know that ISO is relatively voluntary and NIST supplies a control catalog and not policies. So here we have to take the control catalog, and mash our policies into it.”

I wouldn’t call this “kinda good” at all :)  These control catalogs only provide a hierarchy within which to look for evidence of  our ability to resist an attacker.  They are incapable of making any claim about the effectiveness of the controls when they are operated at 100% efficiency, or more importantly, what % efficiency our specific organization operates at.

Let’s use Chris Hayes’ Initech as our fictional example.

Initech has a control (a back door on a loading dock).  Now the locks on the door are 100% capable of locking the door.  This is different than saying that they are capable of frustrating all but the top 5% of lockpicking burgalars.  It is also diffferent than saying that in a sample of several “walk around audits” the doors are left open 20% of the time (they are not in compliance with policy 100% of the time).  Even worse, that 80% of the time the door is not propped open?  Yeah, tailgating is a known issue.

So we have several different variables here that we need to account for (and it’s just a door).  But the analogy stands that most “risk management” methodologies are “We have a door, yes/no?” And most GRC platforms, when asked for their “opinion” will simply say “door is needed” or, even worse, “a door policy is needed”.

3.)  Criticality and the Source of Value is all messed up in these Risk Management models.

Chris writes:

Someone wants me to tell them which boxes are more critical than others. This is mainly because of budgetary or operational reasons. To which I usually say “All of them, it is a system after all”.

This literally made me laugh out loud.  And this sort of “rate the firewall as Risk = 500 but rate the actual business application as Risk = 157″ thing is also endemic.  Now Chris is very smart here.  He correctly identifies that the value is tied to the business process the systems support, and not to a specific box.  Oh, we scan at the specific box level - but because of the nature of systemic failures - all the boxes in the process are inexorably interrelated.

One of the reasons I really like FAIR is that the losses are quantified (or qualified) based not on some amorphous value of the box or the process itself, but losses are linked to the actions that the threat will take. Take systems in a highly regulated industries as an example.  Usually the most probable losses aren’t due to system compromise per se, but in the disclosure the compromise causes (regulators are a threat source, after all).  But many “risk management” methodologies will say “online banking is worth $2 billion, the value of the systems is therefore $2 billion”.  And suddenly we’re telling executive management that there’s a 60% probability that they’ll lose $2 billion.

4.)  If the primary source of prior information for your “risk management” methodology is a vulnerability scanner - you’re doing it wrong.  Chris writes:

So we ran a scan and now we have a report. A snapshot in time to make all decisions. Where did these vulnerability ratings come from? Do I even know if my system is at risk? What if I spend my time on vulnerabilities that have no threat?

So first, my thoughts are that actual “vulnerability” must be a comparison of the force a threat can apply, and our ability to resist that force (this is a probability statement, btw).

Changing your thinking about vulnerability now helps us understand the problem in several new ways.  First, you can start to divorce yourself from the scanner.  After all, the scanner is simply providing you with current state information that is usually just relevant variance from policy. It doesn’t really tell you about real “weakness in a system” because the system is an interrelated mess of people, processes and IT assets.

5.)  Finally, most “risk management” approaches just *don’t* do a good job of helping us understand the how’s and why’s of managing risk. In the past, I’ve referred to these standards as really being “issue management” because they are at their heart, an act of discovery - a formal process around gathering prior information.  They are not, in and of themselves, capable of linking the issues discovered to the root cause.  And these root causes?  Yeah, they’re the things that create “risk”.  Not a threat, not a vulnerability, not the existence of an asset - the amount of risk that we have stems from our capability to manage it.

So Chris, I completely agree - but I wouldn’t give up yet.  There actually are a few of us who are focused on what you suggest:

Where to go from here: A fundamental revamp of how to deal with Risk. Where risk professionals focus on the treating the sickness and not the symptoms, and come up with some new success/actionable metrics.

Chris, there’s nothing I want to do more than that.

Apple added access for iPhone and iPod touch users to a subset of its iTunes Store over Wi-Fi--the awkwardly named iTunes Wi-Fi Music Store--more than a year ago, along with the ability to access that store at no cost from handhelds and laptops via Starbucks outlets in New York, Seattle, and throughout the San Francisco Bay Area. (Chicago and Los Angeles have been "coming soon" for a year, but the new AT&T/Starbucks deal may have delayed opening up those markets.)

Terrestrial AM/FM radio stations would like to figure out how to remain meaningful in a world of streaming Internet radio. Their latest strategy is to embed information that allows a listener to mark a song they want, potentially getting a piece of music sold in this fashion. With FM tagging, Zune players tap into an existing very low-data-rate encoding protocols that allow stations to push out their call letters and current song information. By adding a very short code, broadcasters can allow Zunes to look up the appropriate song.

At launch, 450 stations from major networks, including Clear Channel, Entercom, and others, will broadcast tagging details. Note that Microsoft includes KEXP, a Seattle independent and alternative radio station, in its sample image, for the new models. KEXP, given a boost a few years ago through significant short-term funding by Paul Allen--funding that involved changing its call letters to his Experience Music Project museum initials--has an enormous listenership over the Internet ironically enough. KEXP will be a programming partner creating channels of music for the subscription-based Zune Pass service. (Zune Pass is $15 per month, all you can eat.)

This option could allow Microsoft to ink partnerships with hotspot networks to brand them with Zune compatibility, lets radio stations promote something other than iPods that they would have a direct relationship with (and, potentially, some kind of revenue stream from?), and may be part of breaking Apple's digital music hegemony. May be. Nobody's gotten rich betting against Apple for the last several years. (Details of revenue sharing with radio stations hasn't been discussed.)

Apple opted for a partnership with HD Radio broadcasters and equipment makers that has a relatively elaborate process of tagging songs. HD Radio is digital AM/FM, a patented and licensed method that has provoked a lot of controversy, and has lagged enormously in the marketplace, despite well over 1,000 stations (including many public radio stations) broadcasting in this digital format, some for over three years.

HD Radio tagging requires an HD radio receiver with a Tag button; pressing that button stores the song's tag information. The radio must also have an iPod dock. Docking an iPod syncs the tag information, and the next time the iPod is sync with iTunes, you can see which songs were tagged. Kind of tedious compared to "press a button while listening to an FM station and buy the song over Wi-Fi." (I've been writing about HD Radio for years, and even launched a blog that's gone moribund; the technology is interesting, but Internet radio on mobile devices coupled with on-demand music purchasing over cell and Wi-Fi may simply make HD Radio unnecessary for listeners.)

Microsoft has a more compelling "marketing story" for this feature than Apple, that's for sure. On the other hand, do you really need to tag songs from stations that play only the most popular music in a given format?

So I put together a simple class that holds an XmlDocument and implements ISerializable and called it SerializableXmlDocument. I'm sharing the source code here in the hopes that

a) somebody will find it useful, and

b) somebody smarter than I am will point out how I screwed it up and help me make it better.

SerializableXmlDocument includes implicit conversion operators to make it easy to convert to/from an XmlDocument. It holds the actual document in a property called Value. This "isomorph" pattern is one that I picked up from Craig.

While writing this code, I also wrote a helpful extension method for getting a byte array out of a MemoryStream that is exactly the length of the data written to the stream so far (CopyUpToSeekPointer). So don't go looking in the docs for MemoryStream for this method :) This is obviously not the most efficient way to consume bytes written to a MemoryStream since it copies the data into a new byte array, but it's very convenient in many scenarios.

Here is SerializableXmlDocument.cs:

using System;
using System.Runtime.Serialization;
using System.Xml;
using System.IO;

namespace Pluralsight.Samples
{
    [Serializable]
    public class SerializableXmlDocument : ISerializable
    {
        public SerializableXmlDocument() { }
        public SerializableXmlDocument(XmlDocument value)
        {
            this.Value = value;
        }

        public XmlDocument Value { get; set; }

        #region ISerializable implementation
        public SerializableXmlDocument(SerializationInfo info,
                                       StreamingContext context)
        {
            byte[] serializedData = (byte[])info.GetValue("doc",
                typeof(byte[]));
            if (null != serializedData)
                this.Value = Deserialize(serializedData);
        }

        public void GetObjectData(SerializationInfo info,
                                  StreamingContext context)
        {
            byte[] serializedData = null;
            if (null != Value)
                serializedData = Serialize(Value);
            info.AddValue("doc", serializedData);
        }
        #endregion

        #region implicit conversion to/from XmlDocument
        public static implicit operator SerializableXmlDocument(
            XmlDocument doc)
        {
            return new SerializableXmlDocument(doc);
        }
        public static implicit operator XmlDocument(
            SerializableXmlDocument sdoc)
        {
            return sdoc.Value;
        }
        #endregion

        #region Xml serialization helper methods
        private static byte[] Serialize(XmlDocument doc)
        {
            MemoryStream stream = new MemoryStream();
            doc.Save(stream);
            return stream.CopyUpToSeekPointer();
        }
        private static XmlDocument Deserialize(byte[] serializedData)
        {
            XmlDocument doc = new XmlDocument();
            doc.Load(new MemoryStream(serializedData, false));
            return doc;
        }
        #endregion
    }
}

...and here's the CopyUpToSeekPointer extension method for MemoryStream:

using System;
using System.IO;

namespace Pluralsight.Samples
{
    public static class MemoryStreamExtensionMethods
    {
        public static byte[] CopyUpToSeekPointer(
            this MemoryStream stream)
        {
            // copy only the part of the buffer
            // that contains the serialized document
            long length = stream.Position;
            byte[] buffer = stream.GetBuffer();
            byte[] result = new byte[length];
            for (int i = 0; i < length; ++i)
                result[i] = buffer[i];
            return result;
        }
    }
}

...and here's a sample object that uses SerializableXmlDocument:

using System;

namespace Pluralsight.Samples
{
    [Serializable]
    public class Item
    {
        public string Name { get; set; }
        public SerializableXmlDocument Data { get; set; }

        public void Print()
        {
            Console.WriteLine("Name: {0}", Name);
            Console.WriteLine(Data.Value.OuterXml);
        }
    }
}

...and here's a sample program that creates an instance of Item, serializes it, then deserializes it, printing diagnostics along the way to show that it's working properly.

using System;
using System.Xml;
using System.Runtime.Serialization.Formatters.Binary;
using System.IO;
using Pluralsight.Samples;

class DemoProgram
{
    static void Main(string[] args)
    {
        XmlDocument doc = new XmlDocument();
        doc.LoadXml("<root><child>text</child></root>");

        Item item = new Item
        {
            Name = "Testing 123",
            Data = doc,
        };

        // print object before serialization
        item.Print();

        BinaryFormatter formatter = new BinaryFormatter();
        MemoryStream stream = new MemoryStream();
        formatter.Serialize(stream, item);

        byte[] serializedItem = stream.CopyUpToSeekPointer();

        Console.WriteLine("Serialized data (base64): {0}",
            Convert.ToBase64String(serializedItem));

        item = (Item)formatter.Deserialize(
            new MemoryStream(serializedItem, false));

        // print object after deserialization
        item.Print();
    }
}

Here's the output of the previous sample program:

Flame away!