What's my take on the summary of changes? Most merchants will be pleased to see that these are relatively minor changes...]]> Mon, 18 Aug 2008 20:00:00 +0000 payment card industry data security standard release represents version pci dss summary october pdf minor PCI Compliance: Reaction to the Summary of Changes http://securityratty.com/article/a930349b033e6f56c6098e0b152daddf http://securityratty.com/article/a930349b033e6f56c6098e0b152daddf Meraki reworks product line, drops new sales of community flavor: The cheap mesh router company has mutated slightly once again. The partly-Google-backed firm founded by MIT RoofNet "graduates" built the company on the notion that they could sell $50 routers that could mesh with each other, and use a robust central management system they developed. Over time, the $50 price didn't hold up for commercial networks of scale. Last October, the company mishandled a change in its business model when they abruptly announced a $100 increase in price for newly purchased nodes under their Meraki Pro level for any network that wanted to control whether or not ads appeared, have user accounts, and charge for service. (They eventually recovered, apologized, and reworked some of the transition details.) The company continued to offer a $50 indoor and $100 outdoor Standard level nodes for networks that required ads and had other limits. As of a few days ago, Standard is dead, and the Meraki mini has been upgraded to the Meraki Indoor ($150). The Indoor has signal strength LEDs on the side for better help in placing units, an internal antenna, and better resilience against power fluctuations. The company explains its move in eliminating Standard by noting that most customers moved to Pro. It's not precisely the end of idealism (nor did that happen last October), as Meraki is still one of the major commercial mesh vendors, and their products are still vastly easier and a fraction of the cost of higher-end competitors.

New life for dead Tempe network? Another firm has expressed interest in buying the pennies on the dollar assets that remain of the former Kite Networks installation in Tempe from the firm that financed the venture as long as they can negotiate a new, more favorable deal with the city for mounting and removal rights. CTC, Inc., which the East Valley Tribune reports runs networks in the Kansas City, Mo., area, thinks there's an opportunity. The article notes that reception problems were due in part to the prevalence of stucco in Tempe, common in the southwest. Stucco walls layer plaster or other materials on a wire mesh for strength that turns a house into a bit of an accidental Faraday cage, partially shielding the home from electromagnetic radiation. (Could I go so far to say that Tempe's network could be a phoenix? Ouch.)

Wake up, you darn computer: Intel's new Remote Wake motherboards won't work with Wi-Fi, it's important to note. The feature, announced today, will let an incoming VoIP call (the articles all say "phone call over the Internet") to wake a computer, as long as the call comes from a particular source. Of course, the standard SIP protocol for VoIP doesn't have the kind of security and integrity that would allow this; Intel has to overcome the problem with network address translation that renders most computer unreachable from outside the local network without a separate service like GoToMyPC or LogMeIn; and it will only work for computers connected via Ethernet to a local network, because Wi-Fi is off when a computer sleeps, while Ethernet can remain lightly active. I don't have the protocol details yet, but there's long been a Wake on LAN protocol that required support in a router, operating system, and Ethernet card; Intel may be leveraging this.

Today, allow me to update you on FAIR and the movement towards a formal, open standard.  There’s a couple of cool things going on in our little risk-world.

First, The Open Group Security Forum continues to move towards a formal adoption of FAIR.

WHAT DO YOU MEAN “WE” - YOU GOT A STANDARDS BODY IN YOUR POCKET OR SOMETHING?

Our meeting in Chicago a few weeks ago was great, but also slightly disturbing for me. I got pronoun-confusion syndrome.   I’m used to using the “we” pronoun to refer to RMI, or Jack and myself as we vet the models.  So without even thinking I would said “we have been looking at how loss occurs, and may want to change the model some” and The Open Group Members freaked out (rightfully so).  Adrian Seccombe gently reminded me that the “we” was now the Security Forum, and that “we” didn’t go changing things at will without vetting against each other.  Man I love this stuff.  I get to run our thoughts and ideas past some great folks now - you know, those smart people who tend to have really complex problems and are trying hard to solve them.

Formal Adoption:  Soon, Very Soon Now

Formal Adoption basically means we’ve made this document, everyone is close to saying that they generally like it, and once that finally happens then “bam”, we’re ready to move onward and upward with better things (see Cookbooks, below).  We’ve got a couple of changes to the current document that have been requested that aren’t a big deal.  For example, one request is that we make some statement about general applicability of FAIR to risk domains outside of the IT realm.   But once additions like that and others are done, this long process should be complete.

New Document Moving Towards Public Release:

We’ve got a basic document that should be public in the next few weeks on “What Makes a Good Risk Assessment Methodology” - written by yours truly and Jack.  It’s a very high-level document, and serves two purposes:

• For novices it helps parse out what is important in any undertaking to understand corporate risk (the repeated discussions on the ISO 27001 mailing list make me think it would be a place ripe for such a document).
• For those who “know” risk, it helps to re-establish some fundamental principles like the use of scales (ratio, please), the implications of dealing in probabilities, what attributes like consistency and defensibility mean, how “risk” should be reported to the business (something you know, meaningful) and so on.

When this doc is deemed ready for public consumption I’ll be sure to post on this blog here.

COOKBOOKS, EUROPEAN AGENCIES, AND, IRON CHEF “RISK” - WHOSE CUISINE WILL REIGN SUPREME?

One interesting thing that came up in the Chicago meeting was that ENISA (The European Network and Information Security Agency) developed a very nice document that reviewed something like 18 different risk assessment methodologies against their Criteria for Goodness.  FAIR was one of the ones they reviewed, and we (the royal “we” used there to include all us FAIR-Folk) did awfully well.  Things of interest:

1. They based their work on the current introduction paper which is not at all a step-by-step guide towards an organizational risk assessment (what ENISA really wanted) and we did pretty well.  Well enough that if we had developed a paper along the lines of NIST 800-30 or OCTAVE for the use of FAIR in a formal process, we could have done really, really well.  Like won-the-bake-off kind of well.
2. FAIR is actually not at all incongruous to many of the risk assessment methodologies offered, and in fact compliments many of them by letting those methodologies develop real, structured probabilities.  Think OCTAVE, where they basically say “math is (probabilities are) hard, so if you want to do them for reals, good luck!  But here’s a nonsensical way to do things if you want to believe in magic-fairy risk“.  FAIR fits right in there by stomping on the magic-fairy risk with the jack-boots of rationality.  FAIR similarly helps other risk standards that might lack structured probability development.

So The Open Group Security Forum decided that though we could create a new document and totally p0wn any future ENISA bake-off, there wasn’t much demand for the development of that documentation by the membership  - a point which was made quite apparent at the beginning of the discussion when one large European company CISO asked “What’s ENISA?”  Relevancy is everything, I suppose.

But that second item up there - the one about helping rather than competing with other “risk assessment methodologies” - really struck a chord.  So “we” (The Security Forum) are going to develop some “Cookbooks” that basically are high-level documents that say “If you want to use FAIR with (OCTAVE/COSO/CoBIT/Whatever) here’s how it fits, makes it better, and improves your life.  I’m pretty excited about these, and our first document looks like it’s going to be COSO integration.

THE OPEN GROUP SECURITY FORUM - THEY’RE A TRUSTING BUNCH (WITH QUALIFICATION, OF COURSE)

Finally, many people have asked me “Why work with The Open Group?”  There are many reasons, to be sure, but I will give you one example.  Members of the Security Forum there are not only great at vetting the model and getting consensus on risk and risk factors - but they’re quick to start applying.  So in Chicago, I thought I’d be talking about FAIR and the standard and fighting groupthink.  Nope.  Not at all.  In fact, the forum members spent more time suddenly discussing use of FAIR in a new Trust Model they’re developing.  So all of the sudden, I’m part of a new and exciting project to develop a Trust Model - how cool is that?  While formal adoption of the Trust Model will be necessarily long and deliberate - the collaboration and development is happening much faster than I can keep up with.  But if you all will allow me, it will help me get my head around it all by blogging about it later this week.  So be prepared to read about me dealing in “Trust” a little bit.

If you still subscribe to fixed site recovery services using shared IT infrastructure from the likes of HP, IBM BCRS, or SunGard, among others, you will quickly become a dinosaur in the next 1 to 2 years.

These types of shared infrastructure services involve lengthy restores from tape and a recovery time objective of 72 hours, at best. Plus, you'll be lucky if you recover at all because chances are, you've had trouble scheduling a test with your service provider and it's been a LONG time since the last one, if indeed you’ve ever tested.

72 hours recovery just doesn't cut it anymore. And frankly, understanding your provider's oversubscription ratio to shared infrastructure to determine the risk of multiple invocations, or attempting to negotiate exclusions zones and availability guarantees is a time suck. Most companies are either taking DR back in-house or, if they still rely on a DR service provider, they are using dedicated infrastructure.

A dedicated infrastructure is attractive as it enables replication to improve recovery objectives. But it’s expensive, and puts advanced IT recovery out of the reach of many companies who can't measure downtime in millions of dollars.

But, there are new services on the horizon that will make advanced IT recovery affordable for the masses. This month SunGard announced the availability of its new Virtual Server Replication Service. As I discussed in my most recent Forrester Wave™ of DR Service Providers and other reports, server virtualization is transforming IT recovery. With replication to a virtualized server infrastructure and shared storage infrastructure, customers can enjoy improved recovery-time and recovery-point objectives without the cost of dedicated and custom IT recovery solutions from the DR services provider.SunGard is the first DR service provider to productize these virtual services. I expect other DR service providers to follow suit.

So, the next time your contract is up for renewal, you need to completely rethink your approach to IT recovery. Get off tape and move to these new virtual services. It will improve your recovery capabilities and you don't have to worry about the oversubscription issue with shared virtual infrastructure -- the DR provider can manage capacity much more easily in this environment. In fact, SunGard is offering an RTO SLA of 6 hours as part of the offering. To my knowledge, this is the first time a DR service provider is offering this as part of a standard contract. I'm looking forward to the day when vendors will offer most services with transparent, subscription-based pricing, and standard contract terms that don't take a team of procurement professionals to negotiate. 

ScienceLogic: How long have you been involved in InteropNet?

Katsev: I started at Coyote Point 3 years ago and InteropNet 2006 was my first “big” assignment.  This was the first time Coyote Point had put in a proposal to participate, so we were very excited when we were selected.

ScienceLogic: How long has Coyote Point been involved in Interop overall?

Katsev: We’ve been exhibiting at Interop for a number of years, and after seeing the InteropNet in action, we decided to submit a proposal in ‘06.  We were actually one of the first companies in the load balancing/traffic management space (we’ve been doing this for almost 10 years), so we have a lot of experience to share with InteropNet.

ScienceLogic: What is your role at Coyote Point?

My official title is “Engineering Project Manager”.  Basically, that means that I’m in charge of product releases and maintenance.  It sounds like a weird title for someone participating in InteropNet, but I’ve actually found it extremely useful since my position means that I don’t get to see our systems out in the field a lot.  We’ve added several features and have ideas for others just from my experiences at InteropNet.

ScienceLogic: What do the Coyote Point products do?

Katsev: Coyote Point makes a Traffic Management appliance called Equalizer.  What this means is that any traffic destined for a datacenter’s servers goes through our appliances and we make sure that the server which is best equipped to handle it, does.  Our systems sit between the clients and the servers and monitor the client traffic and the state of the servers.  If the clients start sending more traffic, we’ll balance it out so that no server is overloaded.  If one of the servers stops responding or starts responding very slowly, we’ll steer traffic away from that server.

ScienceLogic: In what way are your products being used as part of InteropNet?

Katsev: In the InteropNet, we’re utilizing a lot of our expertise:  We’re making sure that traffic is balanced and servers are redundant for show services such as DNS and SMTP.  We’re also using our geographic load balancing technology to ensure that the ScienceLogic EM7 appliances and some other internal NOC services are available from anywhere, with the lowest latency, with our SSL acceleration and GZIP compression technology.  Finally, we’re helping logistics in the NOC by allowing a physical separation between systems located in the NOC and those in an emergency rack outside of the NOC.  If either of these two locations were to fail, the network will continue operating without a glitch.

ScienceLogic: Are there any special considerations for Interop that cause you to deploy your systems there differently that any other place?

Katsev: Interop is definitely different than most of our customer installations.   One difference from a standard environment is that the network (at least this year) is one large flat network, with pieces carved out where extra security is needed.  Because of this, we can actually run our failover pairs of Equalizer systems in a non-standard configuration where the two peers are in different racks, or even on different floors.  That’s one of the things that I really like about InteropNet — it definitely brings new ideas to mind, which end up becoming ’special configuration’ white papers after the show.

ScienceLogic: Has InteropNet taught you anything that caused you to actually change your product?

Katsev: In addition to the failover configuration differences I mentioned above, participating in InteropNet has actually caused us to add several new features and allowed configurations.  One example is the “no-spoof” option for Layer 4 clusters.  Prior to the 2006 shows, we always ’spoofed’ the client’s IP address when talking to a server so that the server would see the client’s IP address instead of our own.  At Interop, we ran into a special configuration which would’ve been very difficult to set up in this manner, so our engineers added this feature, and it’s been very a very popular configuration with our customers ever since.

We have also had a couple of business relationships that extended outside of the show.  In 2006, we had a good experience using Spirent Communications gear to benchmark the network, so we ended up purchasing a couple of these systems to test our products.  More recently, we have found a way to bundle our Equalizer e350si load balancers with the ScienceLogic EM7 collector appliances to help ScienceLogic get the best performance in load balancing large quantities of syslog messages to be processed.  If it wasn’t for our participation in InteropNet, neither of these relationships would’ve happened.

ScienceLogic: What’s the best part of being involved with InteropNet?  What do you most look forward to?

Katsev: InteropNet is an amazing networking opportunity (no pun intended).  The group of engineers that put the network together every year is, well, amazing.  There is so much combined experience that any question instantly has several possible answers, and the best answer is chosen very quickly.  One of the ’sayings’ at Interop is “if you run into a problem, ask someone… we’ve probably seen that problem before… five times.”  One would think that being part of InteropNet is the same thing, year after year.  However, in the two years that I’ve been part of this (for four shows), there have been huge differences in the way that the network is designed and put together.  These are both because the vendors selected every year are different, and because the engineers who design the network change from year to year.  Somehow, though, when all is said and done, we have a network that works.

ScienceLogic: You don’t have to answer this one if you’re not comfortable… What would you like to see changed with the way things are done at InteropNet?

Katsev: This isn’t a cop-out… I really can’t think of anything I would do differently.  Sure, there are small problems that pop up sometimes, but every project has those, and the people at InteropNet are more than capable of figuring them all out.  In fact, I know that Interop started out as a show to test the interoperability of devices… but I’m still amazed that all of these devices actually talk to each other and “play nice” together.

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• Which problems will be solved and forgotten?
• Which ones will simply go away?
• Which ones will persist and in fact increase?
• Finally, which new ones might emerge?

First, let me bet my ass that "Not knowing what to log" problem will be licked in 18-24 months; at least as far as major regulations go, people will have a pretty good idea a) what  the auditors want them to log (and review!) b) what they need to log for solving their problems. Now, for esoteric log sources (and custom applications) might still present a challenge from that point of view, but for basic "staples" (firewall, network gear, major OS) the mystery will be over (again, see "Tell me EXACTLY what to log for PCI?"  for reference)

Next, the problem of "Log volume" will  definitely get worse, much worse.  One might think that 100,000 each second is a lot of log - but there WILL BE more at many companies! Big application log explosion is coming, fueled by the need to address logging in areas where such motivation was lacking before (basically, custom and vertical applications) as well as harness the power of "uncommon" logs for such tasks as fraud analysis or SOA monitoring. Keep in mind that even though in some areas logging is NOT a preferred way of monitoring and auditing activities (see this discussion on database logs here), application logging will still explode on us...

The problem of "Log diversity" (the fact that most logs all look different in format and meaning) will get worse before it will get better - and better it WILL (!!!) get since standards are being developed. We will see people struggling with all sorts bizarro log data in the coming years. Virtualization, web services and SOA, various ERP applications and even cloud services will increase the diversity of logging in the coming years.

Similar to the above, a problem of "Bad logs" (ones that are subjective, miss key information, require groping for a crystal ball to understand, turn log analysis into dark voodooistic experience or are useless in some other way) will also follow the pattern of the above log diversity problems - it will get worse before it gets better (via the CEE standard effort that now covers the OpenXDAS effort as well!) I noticed that people started asked me questions about "how to do application logging right?" and "what to tell application developers about logging?" which almost never happened in the past. BTW, watch my blog for some uber-fun info on that!

"Getting the logs"  has gotten much easier in recent years; agentless collectors like Project Lasso (which, BTW, just got updated) and grabbing  files remotely via secure protocols made application log collection easier (syslog-NG with TCP transfer and buffering also helped). Next, Windows 2008 will make it MUCH easier for the whole Windows kingdom due to their use of web services (thanks Eric!). However, in the future it might resurface as we try to collect logs from "weird" places, again, clouds come to mind as well as virtual environments (e.g. how do you get logs off a dormant VM?). What's the next frontier in this area? Log discovery - automatic finding and identifying log files on systems in order to analyze and retain them (Yo, my t-shirt-making colleagues... :-))

All this, however, pales in comparison with my favorite "uber-challenge", "Making sense of logs in  an automated fashion" - this baby is definitely not going away in 2-3 years. Much more research is needed to make that "log->conclusion" jump automatically without head-scratching, invoking ancient deities and cursing under ones's breath. Only then we can attempt to reliable handle "proactive logging" (i.e. analyzing various failure or compromise precursors in logs and then predicting the future based on them), another Holy Grail of logging domain.

Anything new will emerge? Yes, I think awareness of the "Logging Gap" problem will grow. "Logging gap" happens when you combine "a need to log" with utter "inability to do so."  For example, this will happen when people will know that they HAVE TO log, say, for compliance, but will have no way of doing it due to application or platform limitations. This will become one of the challenges and special "logging add-ons" will appear to close the logging gap and create additional logs where activity audit is desperately needed, but native logging is not helping to achieve it.

Also, I think people will finally wake up to "Log security" challenges - i.e. producing for use as evidence, compliance attestations, etc. Log security is not getting the attention it deserves, but I think this challenge will finally emerge in full force in the next 2-3 years. My next poll will address that :-)

Anything else I missed? Share away!

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