The problem is that (Chris’ analysis is) completely impractical. I’ll take a recent, and fairly typical situation as an example. I was taking issue with the manner in which remote access was being provisioned for a third party vendor to connect to a system hosted by one of our European business units. To cut a long story short, it was not only a breach of policy but highly insecure. I wanted the access to be disconnected, the business unit director wanted my risk assessment. And he didn’t want to wait for it.

To quote Chris Hayes, spending time on working out the expected effectiveness of controls, over a given timeframe, as measured against a baseline level of force was not going to pacify an angry Italian fearful that my decision was going to cost him money. He wanted my explanation of the risk and more importantly, what I was going to offer as a solution to keep his business functioning

As Chris is someone who actually does this for a living in a large company, and this is typical of his actual day job, I really find Stuart’s “impractical” comment to be, um, misinformed.

Also, I think Stuart mistakes the purpose of a risk analysis.  The purpose of the risk analysis is not to force someone to be “secure”, but to provide knowledge for decision making.  Using it as a “hammer” to knock in the nail of your personal risk tolerance impairs efficiency and in the long run retards “security” as it creates political resentment.  Seriously, who cares if something might violate policy or not in a pre-implementation discussion?  Policies are not stone tablets handed down from on high, they are state-in-time codification of the data owners risk tolerance.  This risk tolerance changes sometimes, and that’s OK.

To that extent, I appreciate (and I’m sure Chris does, as well) that risk analysis does not create rationality in the data owner.  Someone who sees you as a speedbump on the route to progress they may not be ready to appreciate your point of view even if it is stated in the most rational manner possible.   But it’s worth noting (and Stuart’s example is indicative of this point) that risk analysis does not create rationality in the analyst, either.  If one is being so “security minded” as to ignore the risk tolerance of the business owner - we’re bound to get a reaction similar to that Stuart encountered.  In fact, a practical risk analysis like Chris performed on his blog, done in 30 minutes, should identify the critical point of disagreement between Stuart and the data owner (again, Stuart doesn’t own the data, the agitated Italian does).

But let’s stay rational and open to alternatives to what Chris offers.  Stuart states his approach to risk analysis as:

When I need to document a risk assessment I use a very simple form: list the threats, state the level of vulnerability, list the associated operational costs and potential revenue hits. High, medium, or low risk? Describe the controls and options. Write up who needs to do what, and how much of their time it’s going to take. Job done.

At first glance, I don’t think what Chris has done is any less efficient, and it provides greater insight (using Frequency and Capability instead of just ‘listing the threats’).  But what is key here is that Chris’ approach is consistent and defensible.  Less generous risk geeks and CSO’s I know would have no little difficulty with Stuart’s approach.  But to particularly answer Stuart’s main objection (impracticality) I would offer that with practice, Chris’ work is probably quicker and easier than Stuart’s described process as it eliminates much of the ambiguity an immature risk analysis creates - reducing the need for further discussion and arguments with data owners (regardless of disposition or nationality).

Finally the irony of Stuart’s post is that the reason he had this confrontation may in fact be because he was incapable of bringing a salient model for risk to the table, one that identified the factors that create risk and developed a defensible belief statement concerning risk.   We’ll never know if one would have helped him in this isolated instance, but I can tell you that in organizations like Chris’, good risk models and strong risk anlayses create operational efficiencies, reduce costs, and streamlines intra-departmental communications.

The announcement is of course Good News — because once the PCeU is up and running next Spring, it should plug (to the limited extent that £2 million a year can plug) the “level 2″ eCrime gap that I’ve written about before. viz: that SOCA tackles “serious and organised crime” (level 3), your local police force tackles local villains (level 1), but if criminals operate outside their force’s area — and on the Internet this is more likely than not — yet they don’t meet SOCA’s threshold, then who is there to deal with them?

In particular, the PCeU is envisaged to be the unit that deals with the intelligence packages coming from the City of London Fraud Squad’s new online Fraud Reporting website (once intended to launch in November 2008, now scheduled for Summer 2009).

Of course everyone expects the website to generate more reports of eCrime than could ever be dealt with (even with much more money), so the effectiveness of the PCeU in dealing with eCriminality will depend upon their prioritisation criteria, and how carefully they select the cases they tackle.

Nevertheless, although the news this week shows that the Home Office have finally understood the need to fund more ePolicing, I don’t think that they are thinking about the problem in a sufficiently global context.

A little history lesson might be in order to explain why.

Back in 1930’s, Bonnie and Clyde and other US bank robbers were using the new-fangled automobile to flee across state lines — creating jurisdictional problems as a result. The US solution was to make bank robbery (along with auto-theft and other related offences) into federal offences rather keeping them as state-specific infractions. In particular this meant that the FBI could provide federal level policing (tracking down and killing John Dillinger for example).

We have the same jurisdictional issues dealing with cyberspace, with criminals in one country fleecing consumers in another while using systems hosted in a third. The Convention on Cybercrime addresses part of the problem by trying to ensure international consistency where eLaws are specifically needed (which of course is only the case for small parts of eCriminality, fraud is fraud whether eEnabled or not). However, there is limited inter-jurisdictional co-ordination for eCrime investigations — for example Interpol (often incorrectly perceived to be international police force) merely keeps a large database and passes faxes from one place to another.

In practice, most cross-border investigations are done as “joint operations” and the jointness is usually very limited — one force does all the legwork and a liaison officer in the other country deals with local paperwork. There’s usually a quid pro quo element to these joint operations, for budgeting reasons if no other.

What isn’t happening, or at least only in a handful of very specialised areas, is any international co-operation in setting priorities or selecting cases to pursue. Every country is doing its own thing about eCrime, and there’s a widespread impression that any criminal who can operate from “across the state line” is essentially immune from serious investigation.

We identified this problem last year when we (Ross Anderson, Rainer Böhme, Tyler Moore and myself) wrote a report on Security Economics and the Internal Market for ENISA. It’s not an easy one to fix whilst politicians (and populaces) are unwilling to see “foreign” police officers operating in their country, and the establishment of a truly international “cyber police force” seems equally unlikely.

Our policy proposal to tackle the issue harks back to WWII’s SHAEF, which has morphed into similar arrangements within NATO. In essence liaison officers from multiple forces would sit around a single table, working with a central coordinator, to set policy and decide which investigations to pursue. They would then communicate back to their own countries, who have specifically budgeted to provide appropriate assistance. So it’s very like “joint operations”, but the scheme is multi-laterial, and has a true command and control function in the centre — who will quickly learn to shy away from politically sensitive topics and make a real impact on eCriminality.

To summarise then, a welcome to the Home Office for finally finding a small amount of funding for some country-wide ePolicing; but it’s well past time to be working on world-wide initiatives.

• Moderator: Jim Metzler, Vice President, Ashton, Metzler & Associates
• Rowan Snyder, CIO, KPMG
• David Michael, CIO, United Business Media Group
• Joanna Young, Chief Information Officer, Corporate Information Systems & Enterprise Services, Liberty Mutual

Jim: Is the CIO a technical job anymore? For example, inside Liberty there are business projects with an IT component.

Joanna: We are organized to partner with internal business clients or vendors who provide objectives and business requirements. We strive to figure out the smallest amount of an IT investment we can make to get this to work.

Rowan: We have both. Part of the dilemma is that the thing that sells the best is fear. I don’t want to use that to get business.

Joanna: One good example is security from an application perspective. It’s hard to talk about security investments in business terms. We put it into terms like “this is what it will cost us if we DON’T do this.” For example, a solution for spam required us to do research into what it was costing us overall. Once we put it together, the business was all for it. You have to put your business hat on and think “how can I make this important for a businessperson?” If you can’t, you may need to ask yourself why you’re pushing services on them that they may not need.

Jim: Can you give us insight into business-IT alignment? What about governance?

Rowan: Governance is the hardest part of IT. It’s not like the technology is easy. If it’s a business project with an IT component, I don’t usually get involved. It comes down to overall budget. The infrastructure we own and let people know exactly what it will cost to do it. We are a distributed IT firm, there are multiple groups. This is the most distributed and risk-prone organization I’ve worked in. It can be difficult for the business to exert control. It demonstrates risk, in security, compliance, methodologies, etc.

Joanna: Governance has become a word that nobody wants to use. It suddenly implies that IT is the holder of all the money and they are the ones that get to decide. We stopped using that word and position IT as a strategic business partner.

David: We have a highly decentralized IT set-up. We have about 600 globally and around 40 in the headquarters. We have 10 CIOs for each division, and within each division it is decentralized. We try to run each unit as autonomous. This is a close alignment with IT and business. However, then the problem of how do you have commonality between divisions and collaboration?

Jim: How can you minimize risk in distributed environment using standards and procedures?

David: The reality is it can be impractical for an organization. You end up with a patchwork of platforms and technologies. We have to accept that we’ll have multiple solutions. We can attempt to push a standard, but overall have a much more relaxed approach to manage everything. There is a lot of equality between divisions in what they can choose to purchase.

Joanna: Standards are easier to apply the further down the staff you are. The most important thing with any of this is to understand why you are making the decisions. If there is a process and pros and cons are identified, there is a clear record of why decisions were made.

Audience Poll: Everyone raised their hand that MORE standards were needed.

Audience Question: Are there inefficiencies in the data center in terms of energy and green IT? What are you doing about it?

Joanna: Everyone focuses on cars for carbon footprints. But, it’s really buildings…and then data centers. The data center has the same importance as any other efficiency. They need to be running as cheaply as possible. Corporations have a responsibility to make sure they are energy efficient.

Rowan: We recently did a carbon footprint analysis, and found that half of carbon comes from electricity, with half of that from the data center.

David: Every company does have a responsibility to look at its carbon emission globally. Consider international travel, flying, etc. As much as possible, we are not building data centers. We are using other people’s data centers in an effort to get out of the data center business.

Audience Question: How do you balance the good from standards with agile development and possible roadblocks?

Joanna: Luckily agile development is under the CIO’s control. You can see the lifecycle and savings that occur. When I look, I check what the standards are that I’m measuring by.

Jim: Does web 2.0 have any business meaning in your environment? If so, what are you doing about it?

Joanna: I’ve been in IT for 20 years. It’s another component to business IT investment, and has to be presented as such. As IT professionals we have a responsibility to identify what Web 2.0 is, and then translate to see if there is anything the company should be doing with it. Monitor it based on your current portfolio, and consider its impact.

David: It’s pretty important to our business as a media company. I don’t think it means one thing, it’s a term people use to talk about the web and what’s going on online. From mobile, to ajax, cloud computing or mashups - you can draw multiple conclusions. More and more business is being done online. We have a lot of growth opportunities online.

Rowan: Compliance, security, and privacy issues just explode with Web 2.0.

Which of the following initiatives are likely to be a major telecommunications technology related priority for 2007? Mobility is a huge issue.

We’re starting to see traction with mobility.

• The evolution of enterprise mobility:
  • Voice –> messaging –> e–mail –> web, –> business applications –>  instant messaging/presence –> what’s next?
• Cell phone to Smartphone:
  • 1G –> 2G –> 3G

Converging IT Responsibilities

Collaboration, Web/Internet, Desktop Computer, Deskphone/PBX, Mobile Phone and Applications. All of this is under the umbrella of IT. IT departments are not a single cohesive unit where everyone gets along. They have different motivations, budgets, goals, etc.

BlackBerry manages all of these responsibilities in one, forcing these departments to collaborate and work together. This is key for interoperability between these systems, knowing how they work together.

Desktop capabilities are expected in mobility:

• Information
• Collaboration
• Voice
• Transactions
• Presence
• Application

Mobile devices are fundamentally changing the pace of which we all work. You can reach anybody at anytime. This changes business.

All of this is working with data that is behind a corporate firewall.

The big change in IT is that for almost any industry now, the data that you have and you manage is a core corporate asset. It doesn’t matter whether you’re in manufacturing, logistics, or a bakery. Information is king. This has the benefit of moving IT up to a C-level position. You are a core part of your business success. This has benefits, and also added stress.

Voice is still the “killer app” for mobility. Deskphones and smartphones need to overlap into a mobile voice system.

Another up and coming technology is the mobilization of enterprise applications. This provides the ultimate user experience. For example, Blackberry has mobilized the SAP Business Suite on BlackBerry smartphones. SAP CRM access is as seamless and intuitive as email on BlackBerry and incorporates push, alerting, security, GPS, Wi-Fi and media.

Enterprise grade platforms will extend core competencies of enterprise systems to mobile environments.

• Secure
• Reliable
• Manage
• Control
• Administration
• Standardize

Conclusion:

Putting it together: integrating the wireless capabilities of today into the business tools of tomorrow.

The Cisco 7600 OSR consists of a 256 Gbps switching fabric and a 30 million packets per second (mpps) forwarding engine. Its breadth of IP services comes from Cisco IOS, which provides features such as security, enhanced QoS, and destination sensitive services. In addition, the Cisco 7600 OSR allows the migration of existing port adapters from Cisco 7500 series routers, via the Cisco FlexWAN module, giving service providers one the industry’s widest array of interface options in any single platform. This provides service providers great flexibility in deploying the Cisco 7600 OSR for a variety of applications, protects their investment in existing systems, and gives them a practical migration path to the New World Optical Internet.

A Revolutionary Platform For Evolving Networks

The Cisco 7600 OSR helps service providers break through service and bandwidth barriers today, while designing networks to scale for future growth. The Cisco 7600 OSR achieves this through “adaptive network processing,” or the ability to evolve the platform for new IP services without hardware upgrades. Unlike fixed, ASIC-based platforms, which are hardware encoded, the Cisco 7600 OSR relies on the highly flexible Parallel eXpress Forwarding (PXF) technology for scalable performance of services. PXF is a patented, Cisco-developed network processor capable of line-rate IP services delivery that can support new IP services through periodic software upgrades. Each OSM has two PXF processors capable of 12 mpps of IP services delivery per interface card.

“IP+Optical combines the dynamism of the Internet world with the foundation of the transport world, creating an infrastructure that can deliver the services that service providers need,” said Lele Nardin, vice president of the Internet Systems Business Unit at Cisco. “Cisco will continue to add innovative solutions on top of this solid foundation to make service providers better equipped to meet the constantly escalating and changing customer demands for new networking services.”

Pricing and Availability

The base Cisco 7600 OSR system is list priced at $73,000 and the entry level system, with interfaces, start at $100,000. The interfaces modules are priced between $27,000 to $180,000. The Cisco 7600 OSR is available now worldwide.