A Day of Reckoning is Coming

Over at The CMO Site, Terry Sweeney explains that “Hacker Attacks Won’t Hurt Your Company Brand.” Take a couple of minutes to watch this.


Let me call your attention to this as a turning point for a trend. Those of us in the New School have been saying this for several years, but the idea that a breach is unlikely to kill your organization is spreading, because it’s backed by data.

That’s a good thing for folks who are in the New School, but not so good for others. If you’ve been spreading FUD (even with the best of intentions), you’re going to face some harsh questions.

By regularly making claims which turn out to be false, people undermine their credibility. If you’re one of those people, expect questions from those outside security who’ve heard you make the claim. The questions will start with the claim of brand damage, but they might not end there. They’ll continue into other areas where neither the questioner or you have any data. If you make good calls in the absence of data, then that’s ok. Leaders always make calls with insufficient data. What’s important is that they’re good calls. And talking about brand damage no longer looks like a good call, an ok call, or even a defensible call. It’s something that should have stopped years ago. If you’re still doing it, you’re creating problems for yourself.

Even worse, you’re creating problems for security professionals in general. There’s a very real problem with our community spreading fear, and even those of us who have been pushing back against it have to deal with the perception that our community thrives on FUD.

If you’ve been making this claim, your best move is to start repudiating it. Get ahead of the curve before it hits you. Or polish up your resume. Maybe better to do both.

Terry Sweeny is right. Hacker attacks won’t hurt your company brand. And claims that they do hurt security’s brand.

[Update: I’ve responded to two classes of comments in “Requests for a proof of non-existence” and “A critique of Ponemon Institute methodology for “churn”.” Russell has added an “in-depth critique of Ponemon’s method for estimating ‘cost of data breach’.”]

A few thoughts on chaos in Tunisia

The people of Tunisia have long been living under an oppressive dictator who’s an ally of the US in our ‘war on terror.’ Yesterday, after substantial loss of life, street protests drove the dictator to abdicate. There’s lots of silly technologists claiming it was twitter. A slightly more nuanced comment is in “Sans URL” Others, particularly Jillian York, said “Not Twitter, Not WikiLeaks: A Human Revolution.” Ethan Zuckerman had insightful commentary including “What if Tunisia had a revolution, but nobody watched?” and “A reflection on Tunisia.”

That conversation is interesting and in full swing. What I want to ask about is the aftermath and the challenges that Tunisia faces. After 24 years of oppression, it’s going to be hard to build the political structures needed to create a legitimate and accepted government.

The American revolution came after years of discussion of British abuses of power. American perceptions of abuses of power like the Stamp Act combined with slow communication to the King and fast local communication to create a local political class that could assemble in a continental congress. Even so, after the American revolution, we had one entirely failed government under the Articles of Confederation, which was replaced with our current Constitution. But that was followed by the whiskey rebellion.

I bring this up because it’s easy to focus on the mechanics of government while forgetting about the soil in which it grows. Perhaps the digital world, with its ability to connect Tunisians to people living in places where we’ve worked these things out, will help. (For those foreigners who speak Arabic, or those Tunisians who speak other languages.) I’m not terribly optimistic in light of the shootings in Arizona and how quickly the online discourse devolved into “why this tragedy proves I’m right.” I’m also not optimistic given our poor understanding of our history.

I am, however, hopeful that the people of Tunisia will manage to take a collective break from the violence for long enough to work out a Tunisian approach to democracy. What would that look like? Would technology play a role?

Gunnar's Flat Tax: An Alternative to Prescriptive Compliance?

Hey everybody!

I was just reading Gunnar Peterson’s fun little back of the napkin security spending exercise, in which he references his post on a security budget “flat tax” (Three Steps To A Rational Security Budget).  This got me to thinking a bit  –

What if, instead of in the world of compliance where we now demand and audit against a de facto ISMS, what if we just demanded an audit of security spend?

Bear with me here…. If/When we demand Compliance to a group of controls, we are insisting that these controls *and their operation* have efficacy.  The emphasis there is to identify compliance “shelfware” or “zombieware”^1.  But we really don’t know other than anecdotes and deduction that the controls are effective against, or alternately more than needed for, a given organization’s threat landscape.  In addition, the effective operation of security controls requires skills and resources beyond their rote existence.  We might buy all these shiny new security controls, but if our department consists of Moe Howard, Larry Fine, and Shemp Howard, well…

Futhermore, there are plenty of controls that we can deduce or even prove are incident reducing that are *not* required when compliance demands an ISMS.  These controls never get implemented because business management now sees security as a diligence function, not a protection function.

So as I was reading Gunnar’s flat tax proposal, I started to really, really like the idea.  Perhaps a stronger alternative would be to simply require that security budget be a “flat tax” on IT spend for a company.  Instead of auditing against a list of controls and their existence, your compliance audit would simply be an exercise around reviewing budget and sanity of security spend.  By sanity, I mean “this security spend” isn’t really on trips to Bermuda, or somehow commandeered by IT for non-security projects.

Now we can argue about how much that tax would be and other details of how this might all work, but at least when I think about this at a high level it’s starting to occur to me that this approach may have several benefits.

  1. It would certainly be simpler to draw an inference as to whether more security spend increases or decreases # of, and impact of, incidents.  Not that this inference still wouldn’t be fraught with uncertainty, just “simpler” and I would question whether it would be less informative than insisting that a prescriptive ISMS has never been breached.
  2. If the “spend” audit consisted of “were the dollars actually spent” and “how sane the spending was” – it would still be up to the CISO to be able to have a defensive strategy (instead of having just a compliance strategy).  The “spend” could still be risk-based.
  3. Similarly this would help enable budget for effective security department investments ( like, say, a metrics program, training, conference attendance, threat intelligence, etc… ) that would otherwise be spend above and beyond what is currently “required”.
  4. This spend would allow security departments to be more agile.  If our ISMS compliance standards don’t change as frequently as the threats they’re supposed to defend against – it’s pretty obvious we’re screwed spending money to defend against last year’s threats. But a flat tax of spend would allow security departments to reallocate funds in the event of new, dynamic threats to the environment.
  5. This might help restart the innovation in security that draconian security standards and compliance requirements have killed. Josh Corman (among others, I’m sure) is famous for pointing out that compliance spend stifles innovation because budgets are allocated towards “must have’s”.  If you were a start up with an innovative new security tool, but it isn’t on the radar of the standards bodies (or won’t be until the new req’s 3 years from now), only the very well funded organizations will buy your product.  If I’m a CISO with a weaker budget and want the innovative product that my compliance masters don’t require, I’ll never buy it –  all my budget is spent trying to prove I can defeat threats from 2 years ago.

1 Compliance shelfware is a security spend that is done but never implemented.  Compliance zombieware is a control or security spend actually implemented, but never really utilized.

“Of course we have log management.  We have to in order to be compliant.  But it’s just zombieware, nobody ever actually reads those logs or does analysis on them…”

Dashboards are Dumb

The visual metaphor of a dashboard is a dumb idea for management-oriented information security metrics. It doesn’t fit the use cases and therefore doesn’t support effective user action based on the information. Dashboards work when the user has proportional controllers or switches that correspond to each of the ‘meters’ and the user can observe the effect of using those controllers and switches in real time by observing the ‘meters’. Dashboards don’t work when there is a loose or ambiguous connection between the information conveyed in the ‘meters’ and the actions that users might take. Other visual metaphors should work better.

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Unmeddling Housing

For a great many years, US taxpayers have been able to deduct interest paid on a home mortgage from their taxes. That made owning property cost roughly 20% less than it otherwise would have (estimating a 25% tax rate on interest on 80% of a property). So everyone could afford 20% “more” house, which meant that property values inflated until things were in balance again.

It was a good deal for those who were in at the start. But we should also ask, who lost out? First, anyone renting who couldn’t take the deduction. Second, anyone who assumed that this state of affairs would go on forever. Because this week, the chair of the FDIC called for a re-examination of that policy.

Now, this week, Goldman Sachs predicted a 20% drop in Seattle home prices over the next two years, so as a renter, I get to feel a little schadenfreude. But more important, I think, is the chaos of unwinding 50 years of distortion in the housing market.

A great many people have taken the rise in home prices as a bankable truism. Conflating the rise in prices has been a massive increase in the size of houses and lots, underwritten by cheap oil and large highways, but I’m going to mostly set that aside, and focus on the impact of social policy.

Homeownership has a number of downsides. It locks up a tremendous amount of capital in an illiquid investment. It conflates investment and emotional concepts of home. It makes it hard to move when you need a new job.

Now, a government policy to encourage homeownership (uber alles) encourages homeownership. The trouble is, it does so in an unnatural way, and in a way which it now seems appears unsustainable to our bank regulators. That it’s unnatural and unsustainable was always obvious. It’s inherent in the fact that it’s being encouraged. At the margin, there are either people who buy because it’s encouraged, or the policy is an utter failure. So there are people who, without such a policy, would not be homeowners. And homes cost more than they otherwise would.

But after 50 years of meddling in the market, reducing the support for housing is going to be exceptionally complex and chaotic. And the chaos isn’t going to be evenly distributed. It’s going to be a matter of long, complex laws whose outcomes are carefully and secretly influenced. Groups who aren’t photogenic or sympathetic will lose out. (I’m thinking “DINKs” in gentrified urban areas.) Groups who aren’t already well-organized with good lobbyists will lose out. (See previous parenthetical.) Those who believed that the government housing subsidy would go on forever will lose.

Most of all, those of us who lived within our means are going to lose out as the taxpayer “helps cushion” the “unpredictable” changes.

The worst part is, government never needed to get involved.

[This was written in June, I forgot to hit post, so the dates are a little off.]

Referencing Insiders is a Best Practice

You might argue that insiders are dangerous. They’re dangerous because they’re authorized to do things, and so monitoring throws up a great many false positives, and raises privacy concerns. (As if anyone cared about those.) And everyone in information security loves to point to insiders as the ultimate threat.

I’m tempted to claim this as a nail in the coffin for the insider as the most important threat vector, but of late, I’ve decided that the insider is an near-unkillable boogeyman, and so ‘nails in the coffin’ is the wrong metaphor. Really, this just indicates that references to insiders are a best practice, and we can’t kill them. We can, however, treat those references as an indicator that the person speaking is probably not an empiricist, and discount appropriately.

TSA News Roundup

Man wearing shirt which reads 'property of the homeland'

CRISC – The Bottom Line (oh yeah, Happy New Year!)

No doubt my “Why I Don’t Like CRISC” blog post has created a ton of traffic and comments.  Unfortunately, I’m not a very good writer because the majority of readers miss the point.  Let me try again more succinctly:

Just because you can codify a standard or practice doesn’t mean that this practice is sane. There’s plenty of documentation around homeopathy, astrology, biorhythms, and other pseudosciences, but that doesn’t make them any more real.

In other words, just being able to reference a document for repeatability does not make the outcome of those acts real or valid. Almost everyone in that thread has focused on our industry’s ability to create documentation, not on the fundamental problems of creating a defensible method for risk expression.

This is why our standards blow.  And yes, I’m going to expand my focus beyond CRISC/Risk IT and include the 800 series from NIST (including the new releases), the ISO 27005/31000 document, and many others.  They are all very heavy on repeating the same idea that risk management is some OODA/PDCA type cycle and subsequent bureaucratic processes and very thin on the actual establishment of useful risk statements. Look, your P/D/C/A policy/procedures only need to be a few pages, and you certainly don’t need the time, expense, and hassle of certification.  Spending the time and effort to tailor a several hundred page document and get people all certifiable on the subject to fit your organizational culture is just a rabbit trail of waste.

I mean, as weird as OSSTMM is – at least Pete has done a really good job of trying to provide metrics and derivative values of meaning that are repeatable.

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