This normally works pretty well, but there's a court case in Brisbane right now about a hotel giving a room key to someone who ended up sexually attacking the woman who had rented the room.

In civil action launched yesterday, the woman alleges the man was given the spare access key to her room by a hotel staffer.

The article doesn't say what kind of authentication the hotel requested or received.

Sounds like the beginning of a joke, right?  So these two guys walk into a bar…

“The” Bruce Schneier and Marcus Ranum have an article up on TechTarget/Information Security Magazine called, creatively enough, “Bruce Schenier, Marcus Ranum debate risk management“.

Unfortunately, to get to the article, you’ll have to either already be a subscriber to IT Security, a subscriber to TechTarget, or go through the 20 minute process of signing up by giving TechTarget all sorts of “market information” about how you’re really Brandon Walsh, CSO of “The Peach Pit” Industries in Beverly Hills, CA 90210 (phone 714-867-5309).

For those of you who are already a TechTarget person, the link is above.  For those who aren’t, or those who just don’t have the time, I’ll summarize.  The “debate” is kind of awkward because both authors seem come to the same conclusion:

Risk Management, it’s something our profession should do, something humans do naturally, it’s necessary in business, but gosh - we don’t have enough data.

I’m not a cryptographer.  I don’t *nearly* have the insight on privacy and politics that Bruce has.  I’m not deep in IP communications.  I haven’t got a proven track record of innovation in IP Security products like Marcus has.  But here’s the thing, I hope you’ll never hear me pretend that I have the skill set to speak authoritatively on those subjects.  Heck, I wouldn’t claim to be a “risk” expert because I have a some insight into my shortcomings and what is needed to tackle such a complex problem.  But such a tepid article on something that (at least I think) is so important kind of, well, confuses me.

Why is it such a boring article?  I’m not sure.  Maybe because they’re just two guys who would rather debate the merits of specific controls or control activities (after all, their penetration testing debate was a huge success), but there’s no new information in the “debate”.  It’s the same old “insurance companies know risk because they have scads of data and we don’t have that” complaint. You know what?  I’m tired of hearing that line, so let’s talk about it.

HOW DO YOU KNOW WE DON’T HAVE THE AMOUNT OF DATA WE NEED TO DO RISK MANAGEMENT WELL?

Not particularly picking on Marcus, but in the article he uses the common complaint, “We lack the data to do risk management well.”  This mantra is repeated to the point where I’m blase’ about it.  But for some reason, this sentence really jumped out at me this time for two reasons.  It made me ask:

1.)  How do you know we don’t have the proper amount of data?

2.)  Can we even define “well” (i.e. what “good” risk management is) yet?

I really don’t know that the industry, especially concerning IT risk, is mature enough to really conclude that we don’t know (in the case of the former), nor that we can define (latter), conclusively.

PLAYING THE CONTRARIAN

Just because I’m feeling kind of zany this morning, let me suggest something.  Maybe there actually is lots of evidence out there for us to use.  Maybe:

1.)  It’s just that we don’t have particularly good models that provide context.

2.)  When that evidence isn’t an obvious phenomena that lends itself to easy measurement, we throw our hands up in disgust and fall back on “lack of data”, “can’t quantify risk”, “best practices work just fine” or any other number of arguments, no, excuses we use to justify our inability to be precise about the past (more or less the present or future - apologies to Niels Bohr).

IT’S IN THE WAY THAT YOU USE IT

Now I actually am happy to acknowledge that we don’t have enough data to be precise.  You, me, even smart guys like Marcus and Bruce - we’ll never be able to “engineer” risk management.  But you know what?  Neither can Insurance companies.  Sure, there are plenty of places where they have enough data to apply a traditional frequentist approach to risk valuations.   But there are plenty of times Insurers actually insure and they don’t have centuries or decades of data.  There are plenty of times when they rely on the “estimates” of subject matter experts.  There are many times they have enough information to be accurate rather than precise, and that’s good enough for them.

For that matter, it’s worth noting that there are plenty of scientific disciplines that have to deal in imprecise prior information, or evidence that’s fraught with uncertainty (what Ranum calls “squishy”, and what I’ve heard real honest to goodness physicists call “noisy”).  Unfortunately, we’re going to be like them.  Until we can read minds and predict the future, there will always be uncertainty in our measurements and posterior conclusions.  The trick is in how you deal with it and express it.  And while I really don’t know how much time Marcus or Bruce have really spent in the deep end on the subject of risk and its management - I have seen people doing brilliant things around risk (though they just aren’t mainstream).  Whether the tools are Bayesian methods, Monte Carlo engines, reductionist models of complex problems, there are risk analysts trying to deal with the problem.  These analysts are applying scientific method(s) and developing reasonable approaches to a very complex problem.  There are people trying, and our body of knowledge is growing, growing well beyond “gee, I haven’t got an obvious solution so I’ll blame it on lack of data”.  Heck, I’ve seen readers of this blog suggest Douglas Hubbard’s book in other security forums!*

I’VE GOT YOUR DATA RIGHT HERE…

But we don’t have enough data?  I have to ask, how much more do we need?  I mean crikey, JPMC just visited our ISSA chapter claiming, like, a bajillion events an hour.  There’s not one, but several companies out there that will want to tell you about how they have deep “insight” into the attacker community.  The boundaries of IT Risk losses are pretty well established by events that happen to public companies.  We have pretty mature testing/assessment tools and methodologies now that help us test our ability to resist the force an attacker can apply to us.  So what part of the Threat Landscape, Asset (Controls) Landscape, or Loss Magnitude landscape is too incomplete (and what are you doing to find the information you need)?

SO WHY DO WE FAIL?

Which brings me to a final, somewhat depressing conclusion.  Maybe there’s data, and maybe we’re starting to see the means to use it.  But in the end I do have to agree with Marcus that the vast majority of the infosec world *is* doing a really, really bad job with regards to “risk” and “risk management”.  The majority of people I know consider GRC to be a cruel, expensive joke.  Risk Assessment Methodologies tend to be built on the faulty premise that if we create a repeatable process, our measurements and conclusions will magically become accurate and wise.  Risk models tend to be factors loosely measured by ordinal scales and then somehow “multiplied” together to create a relatively meaningless qualitative value.  The State of the Union here is not good.  But after reading such a superficial treatment of an important and complex subject, I am left wondering if Bruce and Marcus were the right people to write about risk management in a mainstream publication.  As Inspector Callahan says, “A man’s got to know his limitations.”

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* Speaking of which, if you want to do one cost effective thing to address your uncertainty - go find Douglas Hubbard’s book. It’s even got a nice recommendation from Peter Tippett.  The book is called “How To Measure Anything” - the title sounds rather hyperbolic, but there are good techniques in it we can use to identify useful information and refine our ability to frame that qualitative information into quantitative values. The key is how Hubbard has you deal with your uncertainty.  For those of you who are more scientific minded and want to dig deep into the subject, I have on good authority that E.T. Jaynes “Probability Theory, The Logic of Science” is a rather under appreciated work.

We chatted about the growth of the show and how much that growth reflects the industry itself. Since the bust earlier in the decade both Interop Las Vegas and New York shows have grown year over year – not just in attendees and exhibitors but in topics covered in the conference tracks. As any of us who are in the space know, it’s a rapidly changing market and Interop strives not just to cover the latest trends but also to get ahead of them while still making sure that they are relevant.

The show’s mission overall has expanded beyond “just” networking to cover performance and new trends like virtualization, cloud computing and SAAS that all affect network performance. It is a mirror for the demands on the network (and network admins) and the convergence we see going on that make managing the network so complex today.

Responding to criticisms about the lack of interoperability at the show, Lenny says, “Our special sauce is interoperability.” And in fact the expanded mission of the show ensures that there are more interoperability issues to deal with and he invites the community to comment and share feedback on this core mission.

Last, we talked about InteropNet. We’ve loved our participation in it this year for a variety of reasons – from the opportunity to work with other cool vendors in an intensive and real-life/real-time environment to the true sense of camaraderie and “getting it done” that everyone shares on the InteropNet team to the wonderful atmosphere of hard work AND hard play that you have to experience to believe.

We talked with Lenny about how he measures InteropNet “success” and the answer was illuminating. They’ve got high expectations at Interop; they expect the network to just work, so the focus is actually not on uptime and SLAs – that’s a given. “Nothing less than perfection works here.” (Let me tell you, after my horrible experience with the super slow and inaccessible network at the VMworld conference, that is definitely not always the case. Maybe InteropNet should sell its services…hmmmm…) Rather, it’s about being able to showcase technologies and strategies for networking and interoperability – or as we’re interpreting that, basically “walking the walk – which in the end is what InteropNet is all about.

See the full video here.

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.

On the other hand, it's probably a smart idea to screen screeners when they walk through airport security when they aren't working at that checkpoint at that time. The reason is the same reason you should screen everyone, including pilots who can crash their plane: you're not screening screeners (or pilots), you're screening people wearing screener (or pilot) uniforms and carrying screener (or pilot) IDs. You can either train your screeners to recognize authentic uniforms and IDs, or you can just screen everybody. The latter is just easier.