Auditors, PCI, Something Malicious v Something Stupid & the Future
March 8th, 2010 by peter.bassill
Required Disclaimer – All views expressed within this site are the views of the author only and are in no way representative of the employers of the author.
I was recently presenting at the Information Security Executive Summit at a beautiful venue in the Forest of Arden. Following a very well facilitated event, a long 2 days with some other excellent speakers I felt suitable refreshed that many of my peers share the same views on security as myself.
So what was new, if anything? Well no much. It would appear that as much as I preach that you should love your audit and fear your attackers, many IS professionals still fear the audit more than the attacker. As hard as I try, I still find this a very difficult way to think.
Listening to Joshua Corman from The 451 Group (also from the Rugged Software initiative, your suppliers and your own code is Rugged right?) I came to realise that much of what he said is very true. Many IS professionals will of course take the view that they “MAY get attacked, but WILL get fined”. Has Information Security turned a corner in its mission? Have we now become the last bastions of defence against a known known, the auditor or are we as an industry missing the point of our existence?
Different types of auditor?
In my experience, there are 3 kinds of auditor.
- The fresh faced ones, those that came out of university and “did a course”.
- The disillusioned ones, those that left IT or IS after a few years to progress a career in a parallel fashion and “did a course”.
- The enlightened ones, those who reached a high level within an IT/IS/Engineering career (often military or government sector) and became an auditor to further the industry as well as themselves.
Why Fear the Auditor?
So you know you are going to get fined, what are you going to do about it? Let us look at PCI for a moment.
The standard is an interpreted standard. The requirements within the standard are well published and very well known and understood by IS professionals so why is it that many in the industry are having difficulty achieving compliance?
The fresh faced ones will read the letter of the standard and will often defer to a lead auditor. We should be helping these young souls to further their knowledge by showing them why we are doing what we are doing and how it works. Example: Do you really need AV on a read only BSD based web server with no interactive consoles or tools such as SH/KSH/BASH etc?
The disillusioned ones will often find an obscure method of complying with the letter of the standard and will not accept any reasons for not complying with their view.
The enlightened ones will listen to what you have done, will ask you to demonstrate how it works and will then offer advice on how to improve it. A word of warning though, these auditors knows their beans and will spot the wool before you try and pull it over their eyes!
We know the requirements and we understand that we will be audited against what the auditor THINKS the intent of the requirement is and many IS managers think that puts them at a disadvantage? In my mind, this shouldn’t be an issue. We as IS professionals “should” be able to out think the auditors, using the standard as a minimum “baseline” of our own security. Approaching the standard from this direction will allow us to use the audit more as a validation tool that a cause of stress.
Of course this does not mean you leave it to the last minute. That would be foolish. Have your auditor do a full audit at least 3 months prior to your audit date. It increases the cost and means you do the audit twice, but there will be no nasty surprises when you come to the actual audit. When your auditor finds deficiencies (and they will, that is what you are paying them for remember!) challenge them. Ask them how they have seen the issue rectified within similar verticals. If the audit cannot answer that challenge, then you have the wrong auditor!
This approach works regardless of what audit it you are having done. 3 months worth of leg work before the audit is always cheaper that any amount of remediation / stress / capex requests after a failed audit.
Should we Fear the Attacker?
Again some very interesting views were expressed, ranging from the belief that people never get attacked to the belief that people only get attacked if they make themselves a target. One of the more interesting views was that insider threats can not be quantified. I agree that this is the case, but I firmly believe that to attack a business successfully, it is easier done from the inside. One only has to look at the recent data losses over the past 12 months and it is quickly apparent that the majority of losses are from insider threats.
But this brings on the question of what is an attack? Is it simply someone doing something malicious or should be also include someone doing something stupid? I am certainly more worried and more fearful of someone doing something stupid. As a general rule, IS professionals will know when someone does something malicious but monitoring and tracking the something stupid category is virtually impossible.
My View on the Future of IS in 2010?
2010 in many ways is progressing the same as 2009, I am seeing more compliance and regulatory pressure with a general move away from the “something malicious”. Pressure is finally mounting to deal with the “something stupid”, and 2010 is going to become a year of awareness. As budgets decrease IS professionals will be doing more with less. Dealing with the 80% of security, the human aspect, is harder but there are more easy wins that can be achieved with less budget. Shiny metal with flashing lights will take a hit as more IS professionals will turn to virtualization to run internal services for detective and preventative controls and a lot of time will be spent convincing the businesses that data and asset classification is very necessary, especially when looking to move services into the cloud computing model.
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