“We have long had death and taxes as the two standards of inevitability. But there are those who believe that death is the preferable of the two. ‘At least,’ as one man said, ‘there’s one advantage about death; it doesn’t get worse every time Congress meets.’”

~Erwin N. Griswold

Just look at them grow… they’re like weeds. Unfortunately, in this case it’s not a compliment for your sibling’s kids. This particular growth is in the data breach lists at Privacy Rights Clearinghouse, Attrition, PogoWasRight, and others. (And please accept my thanks for the time you all put into this public service; I apologize for not including you all by name.)

I have no doubt these disclosures represent the tip of the proverbial iceberg of data that have actually left the control of those to which it has been entrusted. I also have no doubt that we’ve been given this glimpse into the shoddy treatment afforded many of our most intimate personal details solely through some forward-looking state legislation (thanks, California, for helping to start a good thing in the U.S.).

Let’s just jump ahead of all this piecemeal personal information loss for a minute. (Did the WABAC machine have a “forward??? lever?) Let’s declare it not only inevitable, but also unavoidable, that, for each and every adult American, their name, social security number, top one or two credit card numbers, street address, date of birth, brief genealogy, and a few other interesting data items are known, collated, and cross-referenced.

But, not by legitimate companies like Experian, TRW, and Equifax. Let’s assume that individuals and groups who do not have our best interests at heart have all of these bits of information correctly assembled into mini-virtual-self-referentially-consistent identities, even if they have no “real life” information on the actual person (e.g., photo, current job, salary, type of vehicle, where your kids go to school, etc.). And, let’s assume they have the ability to keep this information current enough to meet their goals of acceptable cash flow for acceptable risk.

[Aside: Is this feasible? How many databases would I have to subvert in order to get most of this information? One at the IRS, one at a credit agency, one each at a few major banks, and maybe a few others? Remember, I don’t actually have to hack in, I can use social engineering, pay someone, coerce someone, steal the back-up tapes, and so on, and on, and on.]

What then? Is it the collapse of American civilization? I doubt it, but I think it would certainly accelerate some good things and some bad things.

The good things might include something like two-factor credit card use at all times (e.g., you have to show a [new government issue?] driver’s license for all card present credit/debit card transactions). But, what would have to change to allow card-not-present credit card transactions to continue to happen (e.g., most Internet orders, catalog phone orders, Chinese food orders, etc.)? What would it take for Americans to embrace single-use credit card numbers, for example? What parts of the infrastructure would have to change? How would we get and carry around these numbers? And so on.

The bad things might include a new state or national ID that would be required by the credit card companies in order to get a “secure” (whatever that would mean) credit card and a lot of high-end establishments that would start accepting only “VMCAMEXD Secure” for transactions over certain dollar limits or that meet certain risk profiles (e.g., buying for delivery to another country). A treaty with foreign countries could require that “secure” credit cards are the only ones accepted in some situations (e.g., buying a one-way plane ticket to the U.S.).

Beyond that, what would have to change at the IRS now that all SSNs are “public”? What about elsewhere in the Federal government? What would this mean to the Privacy Act? And so on. The mind reels, but it still feels like a good thought exercise.

For me, the question is not “What happens if someone else knows all the data associated with me?” The question is “What financially and socially acceptable capability will make it such that I can unequivocally prove that I’m the only me that goes along with my (now public) mini-identity data (e.g., credit card numbers, social security number, address, genealogy, etc.)?” And, in terms of requirements creep, I’d also like to be able to prove it without giving away my actual identity.

Thoughts? I hate to take you this far and not have something to offer, but I feel qualified only in asking the question, not in postulating an answer. And, of course, my follow-up question is “How are we going to make that software better than the software we have now????

Technorati Tags: data security, privacy

Sure, you can’t throw out all your existing code and start over, but you also can’t hide it forever. It wouldn’t surprise me even a little bit to find that your super-slick, Ajax-improved front-end that’s written in the latest Java is actually using a JNI call to kick off some C code that no one knew how to rewrite because it’s calling some COBOL that no one has looked at since before Y2K that may actually rely on some Fortran 77 for a particularly complex calculation. And, of course, your authorization and entitlement database is on some Unix-clone variant on, say, an old IBM mainframe somewhere that talks some weird protocol that only one guy understands (and he’s about to get a gold watch in his stocking). In addition, did I mention that imminent end-of-life notice about both the hardware and the software you’re running on that box in the corner that no one touches (the one that spits out quarterly financials).

If you’re waiting for the one and only security answer to appear before you start making improvements in this installed base, you should probably polish up the old resume. You’re going to be selling yourself before you’re able to sell that wait-and-see strategy. To put an even finer point on it, even if the perfect security solution came along today, it would probably still take you years to get it in place because you’re not set up for success (because you’ve been waiting for the perfect drop-in software security solution).

Software security isn’t going to happen that way. No one knows the one-size-fits-all answer yet, or even if there can be one. But we sure have a pretty good handle on how “…chance favors only the prepared mind” (with apologies to Mr. Pasteur). Even if you can do only a few things, get started.

Institute some governance. If your executive group has application and software security on their radar, then it’s much more likely to get in the budget.

Know your business. You cannot make informed and wise security decisions if you don’t know what you’re trying to accomplish.

Document your software development lifecycle. If you can describe and demonstrate your process, then your process can be improved when the time comes.

Give skill-appropriate awareness training. If your product managers, architects, business analysts, developers, and testers develop a sensitivity to the security issues associated with what they’re working on right now, it will get better. And the next thing will be better still.

Go start now.

Technorati Tags: software security

I was a young Air Force lieutenant when Ken Thompson released his 1984 piece, Reflections on Trusting Trust. Assigned to a data center in the Pentagon, I was working on the B2 evaluation of Honeywell Multics with the fine folks at the National Computer Security Center and contributing some words to the growing Rainbow Series books. We were in ongoing debates over the meaning of phrases such as “top-level specification” and “on behalf of” in the Orange Book (a mail thread that went on for several years) and trying to perpetuate the wave of talking about “trusted computers” instead of “secure computers.”

We talked a lot about “how much trust do I get for how much analysis and testing” and “how much trust do I need for certain scenarios, like allowing a computer to automatically downgrade data from Top Secret to Secret.” These kinds of concepts ended up in capability maturity models, testing models, and risk models.

I took Ken’s words to heart and quickly made up my mind that we could really only move the trust bar up slightly (like from 10% to 20%), even with enormous expense. It was immediately obvious that getting up to, say, 75% would require so much calendar time that no one would wait for the result (and I think later experience with Orange Book evaluations, Common Criteria evaluations, and related programs have borne this out). Between hardware, software, firmware—and the completely unpredictable human factors—we really had no idea how even the most reviewed code would operate in relatively controlled environments (e.g., in a government facility where everyone was cleared), much less how it would operate in a hostile environment (hostile mobile code was not really a problem yet) where people might actively be up to nefarious deeds.

Why should you care about my reminiscing? Well, because I think a flavor of trust is still a major problem today and it’s costing everyone a bunch of money that could be put into real long-term solutions.

As I talk with my operations friends these days, I’m seeing a subtle shift in their thinking. They’re thinking more and more about appliances (web application firewalls, IDS and stuff like that), but not for direct security value. They seem to be thinking that since the software they install, whether purchased or built internally, will certainly have security problems, they have to install more bells and whistles so that operations can protect itself. This is beyond healthy paranoia; it’s an unhealthy distrust of people who should be active partners, even if it’s been earned by years of spectacular failures.

Then I started wondering why so many development organizations throw out requirements documents from product managers and just start over. Is it only because the requirements are so bad, or is it also because the developers just don’t trust the managers to know what they’re talking about?

And why do so many managers try to tell development organization how to create applications, instead of simply what the creation must accomplish? Do they simply not trust the developers to be aware of business objectives, or do they just not understand the creative processes involved?

And so on.

What an enormous amount of wasted cycles that could be used to greater organizational good.

We may never get to the point where we can implicitly trust software. But, can’t we at get to the point where we can trust each other?

Technorati Tags: software security, software quality

The PCAOB is introducing new guidance to help lower the overall cost and, presumably, increase the effectiveness of SOX 404 audits. It needs to use this opportunity to help fix some root causes, not just tell us how to find more symptoms.

This past December, the PCAOB announced that it would propose for public comment a “new standard on auditing internal control…designed to focus the auditor on the most important matters, increasing the likelihood that material weaknesses will be found…” The proposal itself can be found at http://www.pcaobus.org/Rules/Docket_021/2006-12-19_Release_No._2006-007.pdf.

Starting on page 93 of the document, there is a section on “Benchmarking of Automated Controls.” It includes guidance like “Entirely automated application controls are generally not subject to breakdowns due to human failure,” which is clearly not true since bad input makes functional application security controls fail all the time. Telling auditors that automated application controls automatically get a gold star is not a step in the right direction.

It does go on to suggest that the benchmarking strategy take into account the importance of the effect of related files, tables, data, and parameters on the consistent and effective functioning of the automated application. That’s a good thing.

The document then suggests that “If general controls over program changes, access to programs, and computer operations are effective and continue to be tested, and if the auditor verifies that the automated application control has not changed since the auditor established a baseline (i.e., last tested the application control), the auditor may conclude that the automated application control continues to be effective without repeating the prior year’s specific tests of the operation of the automated application control.”

So, never mind that new attacks are discovered with unnerving frequency and that perfectly good code can suddenly become not so great (think crypto algorithms), the apparent recommendation is that if you didn’t or couldn’t poke hard enough to break it over some time period, then it’s okay to skip it later. Approaches like this where we’re considering only functional changes and not testing skill and depth can’t be effective.

How many times has someone walked up and spotted a problem you failed to notice time and time again. As organizations periodically change auditing firms, expect huge increases in reported problems.

The proposed guidance gives the following factors to use when deciding to use benchmarking:

• The extent to which the application control can be matched to a defined program within an application;
• The extent to which the application is stable (i.e., there are few changes from period to period); and
• The availability and reliability of a report of the compilation dates of the programs placed in production. (This information may be used as evidence that controls within the program have not changed.)

This wording is still neglecting changes on the threat side of the equation. Just as many castles were considered impregnable until about five seconds before the first cannonball hit, many lines of code were considered secure right up to the point where the breach story appeared in the newspaper.

The guidance gives the following factors to use when deciding whether to reestablish the benchmarking baseline:

• The effectiveness of the IT control environment, including controls over application and system software acquisition and maintenance, access controls and computer operations;
• The auditor’s understanding of the nature of changes, if any, on the specific programs that contain the controls;
• The nature and timing of other related tests;
• The consequences of errors associated with the application control that was benchmarked; and
• Whether the control is sensitive to other business factors that may have changed. For example, an automated control may have been designed with the assumption that only positive amounts will exist in a file. Such a control would no longer be effective if negative amounts (credits) begin to be posted to the account.

Okay, so if I know that most auditors and organizations use COSO as a governance model, and COBIT 4 to interpret COSO to arrive some IT control objectives, and I consider AI2, Acquire and maintain application software, important to my environment, then I might understand what “controls over application and system software acquisition and maintenance” means above. And, I might even read COBIT and see AI2.4, Application Security and Availability, which states “Address application security and availability requirements in response to identified risks, in line with data classification, the organization’s information security architecture and risk profile. Issues to consider include access rights and privilege management, protection of sensitive information at all stages, authentication and transaction integrity, and automatic recovery.” Oh wait, I only need security software, not software security. Sigh. Another opportunity missed.

There is a need here for any words that introduce something like the following:

The customer may have written their own software that is directly used in the financial reporting process and you, the auditor, should be aware not only of the software’s functional controls (e.g., I&A, encryption, entitlements), but you must also accrue confidence that their internal development practices and testing are sufficient to produce quality software that has at least some capability to protect itself from attack even in the event of catastrophic failures other general and IT security controls being considered as part of this SOX audit. While security software may comprise the majority of IT security controls, software security is the property that gives us confidence in their continued successful operation even in the certainty of ongoing attack. You must use a risk-based approach to accruing confidence, focusing on relevant factors that have a material effect on the software’s ability to meet business objectives even in an overtly hostile environment.

Now we’re thinking more about the problem and less about the symptoms.

Technorati Tags: software security