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Implementing Continuous Monitoring
John M. Gilligan
FedTech Continuous Monitoring Webinar
December 1, 2011
1
Topics
• Background
• What is continuous monitoring
• NIST and FISMA guidance
• Continuous Monitoring in the “Cloud”
• What’s next
• Final thoughts
2
Government Security Environment
• We are in a cyber “war” and are losing badly!
• The IT industry has produced an inherently
unsecure environment—total is security not
achievable
• CIO/CISO mandates exceed time and
resources available
• Cyber security is an enormously complex
challenge—there are very few true experts
It is time to focus on ways to make real improvements in security
3
FISMA Was Well Intended; What was Not Working?
• Original intent was good:
– Ensure effective controls
– Improve oversight of security programs
– Provide for independent evaluation
• Implementation took us off course
– Agencies unable to assess risks
– NIST “guidance” became mandatory
– No auditable basis for independent evaluation
– Grading became overly focused on paperwork
– Failure to recognize emergence of automated tools
4
Bottom Line: High cost and debates about security improvements!
Analogy of “Old” FISMA Implementation
• An ambulance shows up at a hospital emergency
room with a bleeding patient
• Hospital gives inoculations for flu, tetanus, shingles,
and vaccination updates
• Hospital tests for communicable diseases, high blood
pressure, sends blood sample for cholesterol check,
gives eye exam and checks hearing
• At some point, doctors address the cause of the
bleeding
5
Former Policy Regarding FISMA Resulted in a Checklist
Approach
Meanwhile, the patient is
bleeding to death!!
6
We Need Triage--Not Comprehensive Medical Care
FISMA and NIST Guidance
• FISMA Reporting Metrics (6/1/11) requires
reporting on metrics monitored on a
continuous basis
• NIST SP-800-37 encourages continuous
monitoring in support of
certification/recertification
7
Policy and Guidelines recognizing benefits of Continuous Monitoring
What is Continuous Monitoring?
• Monitor security controls at frequency of
attacks
• Recognize that systems undergo continuous
evolution
• Leverage automated tools*
• Focus on highest threat areas (e.g., FISMA
reporting guidance, 20 Critical Controls)
• Implement management reporting to
motivate rapid change (e.g., State Dept.)
8
* Many relevant tools are already being used to perform operations and maintenance functions
Continuous Monitoring in the “Cloud”
• Cloud provider must provide evidence of
continuous monitoring
– Summary of continuous monitoring
implementation—prior to engagement
– Metrics from monitoring and actions taken
• Cloud provider should be able to move quickly
to improve security
– Single provider and single control point
– Less influence from cultural resistance
9
Continuous Monitoring: What’s next?
• Expand number of controls
implemented/monitored—build on initial
capabilities and success
• Leverage integration of tools to achieve true
enterprise view and rapid response capability
• Decrease cycle time toward ‘real time’
monitoring (from every couple of days to
single digit seconds)
• Fully integrate security and operations to
reduce cost of operations and security 10
Final Thoughts
• Federal government with industry support can
lead global improvement in cyber security
• Continuous Monitoring of security control
implementation and enforcement is essential
• In the near-term we must focus our efforts to
make measurable progress
• A well managed system is a harder target and
costs less to operate
11
We Need to Stop the Bleeding—Now!
Contact Information
12
John M. Gilligan
jgilligan@gilligangroupinc.com
703-503-3232
www.gilligangroupinc.com
13
NIST Guidance: 1200 pages of FIPS Pubs, Special Pubs, Security Bulletins, etc.

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Implementing Continuous Monitoring

  • 1. Implementing Continuous Monitoring John M. Gilligan FedTech Continuous Monitoring Webinar December 1, 2011 1
  • 2. Topics • Background • What is continuous monitoring • NIST and FISMA guidance • Continuous Monitoring in the “Cloud” • What’s next • Final thoughts 2
  • 3. Government Security Environment • We are in a cyber “war” and are losing badly! • The IT industry has produced an inherently unsecure environment—total is security not achievable • CIO/CISO mandates exceed time and resources available • Cyber security is an enormously complex challenge—there are very few true experts It is time to focus on ways to make real improvements in security 3
  • 4. FISMA Was Well Intended; What was Not Working? • Original intent was good: – Ensure effective controls – Improve oversight of security programs – Provide for independent evaluation • Implementation took us off course – Agencies unable to assess risks – NIST “guidance” became mandatory – No auditable basis for independent evaluation – Grading became overly focused on paperwork – Failure to recognize emergence of automated tools 4 Bottom Line: High cost and debates about security improvements!
  • 5. Analogy of “Old” FISMA Implementation • An ambulance shows up at a hospital emergency room with a bleeding patient • Hospital gives inoculations for flu, tetanus, shingles, and vaccination updates • Hospital tests for communicable diseases, high blood pressure, sends blood sample for cholesterol check, gives eye exam and checks hearing • At some point, doctors address the cause of the bleeding 5 Former Policy Regarding FISMA Resulted in a Checklist Approach
  • 6. Meanwhile, the patient is bleeding to death!! 6 We Need Triage--Not Comprehensive Medical Care
  • 7. FISMA and NIST Guidance • FISMA Reporting Metrics (6/1/11) requires reporting on metrics monitored on a continuous basis • NIST SP-800-37 encourages continuous monitoring in support of certification/recertification 7 Policy and Guidelines recognizing benefits of Continuous Monitoring
  • 8. What is Continuous Monitoring? • Monitor security controls at frequency of attacks • Recognize that systems undergo continuous evolution • Leverage automated tools* • Focus on highest threat areas (e.g., FISMA reporting guidance, 20 Critical Controls) • Implement management reporting to motivate rapid change (e.g., State Dept.) 8 * Many relevant tools are already being used to perform operations and maintenance functions
  • 9. Continuous Monitoring in the “Cloud” • Cloud provider must provide evidence of continuous monitoring – Summary of continuous monitoring implementation—prior to engagement – Metrics from monitoring and actions taken • Cloud provider should be able to move quickly to improve security – Single provider and single control point – Less influence from cultural resistance 9
  • 10. Continuous Monitoring: What’s next? • Expand number of controls implemented/monitored—build on initial capabilities and success • Leverage integration of tools to achieve true enterprise view and rapid response capability • Decrease cycle time toward ‘real time’ monitoring (from every couple of days to single digit seconds) • Fully integrate security and operations to reduce cost of operations and security 10
  • 11. Final Thoughts • Federal government with industry support can lead global improvement in cyber security • Continuous Monitoring of security control implementation and enforcement is essential • In the near-term we must focus our efforts to make measurable progress • A well managed system is a harder target and costs less to operate 11 We Need to Stop the Bleeding—Now!
  • 12. Contact Information 12 John M. Gilligan jgilligan@gilligangroupinc.com 703-503-3232 www.gilligangroupinc.com
  • 13. 13 NIST Guidance: 1200 pages of FIPS Pubs, Special Pubs, Security Bulletins, etc.