Monday, April 12, 2010

Missing the Point ... Again.

There has been a lot of who-ha (technical term) going around on the changes to Information Security in the Federal government. As the title suggests, there are many, many pundits and "experts" who proclaimed FISMA as a failure and needs an overhaul. It is my opinion that very little will actually change. Why you ask?

Institutional Momentum.

Like most things in the government, the original idea came from DoD and the Intel community. In this way, Certification and Accreditation could be a point in time event because they were running mainframes with hard wired terminals. So things did not change all that often. Systems evolved, web applications were developed, cloud computing, buzz word du jour, blah blah and suddenly the process is broken.

Did you know that certification is only mentioned once in FISMA? And not even the certification that we think of, it concerns a certification authority for digital signatures. Congress did not force the Certification and Accreditation process onto the Executive. If we jump into our way-back machine you may recall a post where I said that FISMA is about risk management. Continuous monitoring and vulnerability management were part of this vernacular from the start. FISMA was perverted into a checklist / table top exercise to keep costs and schedule under control, which is totally permissible if you accept the risk. Some of the feds simply were not ready to implement the NIST recommendations. Some still are not.

You may also know that a few weeks back, SP 800-37 Rev 1 went final. It seems that it has taken just over seven years, but the government produced meaningful recommendations to create a process to manage risk. With this document and the upcoming SP 800-39, we finally move in the direction of strategic risk management. While I have only taken a cursory look at the bills on the Hill, my understanding that there is little in the way of increasing the government’s ability to respond to incidents, perform practical contingency and business continuity exercises or enforce more extensive testing methodologies. I believe this has to do with vendor influences, but I could be completely wrong in my assumptions.

FISMA has done exactly what it was intended to do. Those who didn't/don't/can't understand security, vilified it from the start. Which I felt was an attempt at a self fulfilling prophecy. Lest we forget where we were in 2002. Very little was done beyond a firewall on the perimeter and some A/V on the desktops. Because of FISMA and the thousands (perhaps millions) of findings written, many more technologies have been deployed such as web application testing and intrusion detection. We all understand that we can and should do more, but that is all security programs. This one just happens to be open to regular public criticism. Outside critics should consider the 800 series documents for what they are, guidance for the creation of a solid security program and not as simply a compliance effort.

It would have been better if the new legislation simply said "Do what we already told you to do, but ‘this time with four part harmony and feeling’". Ending with funding for agency staff education and time off to go learn what information system risk management really is.

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