• March 24, 2015

The Four Ps of Standards/Procurement Requirements/”Whatevahs”

Mary Ann Davidson
Chief Security Officer

I am a veteran – not merely a military veteran, but an information security veteran. I don’t get medals for the latter, but I do have battle scars. Many of the scars are relatively recent: a result of tearing my hair out from many, many, many mind-numbing reviews of publications, draft standards and other kinds of documents which are ostensibly meant to make security better, cybersecurity being “hot” and all. Alas, many of these documents have linguistic and operational difficulties that often make it highly unlikely that they will achieve their stated “better security” objectives.

After reviewing so many documents and running into common patterns, I decided to take a cue from my MBA days and categorize my concerns in a catchy way. Though not a marketing major, I vaguely recall the “four Ps” of marketing (product, price, place and promotion) and decided to adapt them to the world of standards/procurement requirements/whatevahs (which I will now refer to as SPW). They are:

Pr    Problem Statement
Precise Language and Scope
Pragmatic Solutions
Prescriptive Minimizations

I t     I offer the "four Ps of SPW" for those who are attempting to improve cybersecurity by fiat, or in other ways intended to compel the market, in hopes that we may collectively get to better security without sinking into the swamp of despair, dallying in the desert of dashed hopes, trekking through the tundra of too-obscure requirements (nice use of alliteration, no?) … you get the point. While I think my advice is generally applicable in the SPW (say “spew”) realm, the context for my discussion is assurance slash supply chain risk mitigation since that’s what I seem to review most often.

Problem Statement

I cannot tell you how many SPW documents I have read in which Someone Was Attempting to Make Someone Else Do Something More Securely, only it wasn’t clear what, exactly, or more importantly, why (or even that the requirements would result in “better security”). Anything that seeks to impose Something Security-Oriented On Someone needs a clear problem statement. Without this, a proposed SPW becomes an expensive wish list with no associated benefits to it. Ultimately, the seller has no idea what the buyer really wants or needs. If a government agency cannot explain what they are really worried about, in language the “comply-ee” can understand, they shouldn’t be surprised if they get a chocolate-covered cockroach (eew) when they ask for something sweet, crunchy and locally sourced. (I’d add “sustainable,” as there seems to be no shortages of cockroaches.)

With regard to security, “supply chain” has become the mantra for attempting to regulate almost 100% of what businesses do. Poor quality, “backdoor boogiemen,” assurance, “supply chain shutdown” are all very (very!) different problems. Worse, the ambiguity around proposing a standard for “supply chain security” may encompass 100% of business operations. Example: my employer does not make their own paper clips or wood stirrers for coffee cups. Do we really need to worry about a shortage of either? No? Then don’t describe “supply chain requirements” that ask technology suppliers to track the wood sourced for our coffee stirrers. Buying a poor quality product, for example, is a business risk. It’s not, per se, a supply chain risk. Furthermore, while poor quality may lead to poor security, not all security problems are a result of quality issues. Some are a result of buyers not understanding that commercial off-the-shelf (COTS) software, while general purpose and often very good, is not “all purpose” and not designed for all threat environments.

The second aspect of a problem statement is the provision of use cases. A use cases is a fancy way of saying, “for example.” Use cases are very important to help turn a problem statement into an “aha” moment for the reader. Moreover, use cases are important to limit scope and ensure that the SPW requirements are appropriate to serve its stated objectives. Absent a use case, you never really know what’s being asked for (and where it applies and where it does not apply). Use cases absolutely need to be contained within a requirements document.

For example, consider the US National Institute of Standards and Technology (NIST) Special Publication 800-152 A Profile for U.S. Federal Cryptographic Key Management Systems Draft 3 (December 2014). This special pub describes a combination of technical standards and policies around cryptographic key management systems. The problem is, nowhere in reading the document is it evident what, exactly, this applies to. Is this just “special, super secret key management systems for classified US government systems?” Or, does it apply to key management for things like Transport Layer Security (TLS) (or other cryptographic protocols that are well-established standards)? Why it matters: because if there are not use cases that define applicability, someone will assume it applies to everything. And, applying these requirements may conflict with (if not break) other standards.

90% of life isn’t showing up, it’s solving the right problem. You can’t solve the right problem if you don’t know (or cannot articulate) what it is, with some “for instances.”

Precise Language and Scope

It is astonishing to me how many SPW documents do not define core terminology used therein. Without a precise set of definitions, nobody really knows what is meant, and if something is vague, it’s going to be misinterpreted. (Worse, an undefined term may end up meaning whatever a “certifier” or other compliance overlord thinks it means: nobody ever really knows if they are compliant if compliant depends on what the certifier thinks it means.) Core terminology must be precisely and narrowly defined within the document. As the famous line goes from Let’s Call The Whole Thing Off,

“You like potato and I like potahto
You like tomato and I like tomahto
Potato, potahto, tomato, tomahto
Let’s call the whole thing off.” (Lyrics by Ira Gershwin, melody by George

The problem is, if a SPW is enshrined and applied, you can’t call it off. At least until the next revision. Figure out what to call a spud and make it clear, please!

For example, in the context of software, what is a vulnerability? A configuration error (leading to a security weakness)? A defect in software (that leads to a security weakness)? Any defect in software (regardless of the impact)? What if the design was intentional? Is a policy violation a vulnerability? A vulnerability cannot, surely, be all the above! And in fact, it isn’t, but just saying “vulnerability” and conflating all the above means that nobody will be able to come up with a remedy that works for all cases. (Note: for configurable software, if you configure it so my grandmother can hack into it, it’s not a “vulnerability,” it’s “user error.” There is only so much you can do to prevent a user shooting self in the foot when we are talking about firearms that allow you to point them at your feet.) Another example, what is a “module?” The answer may be very different depending on whether you are a hardware person or a software person.

If ‘it’ is not clear, ‘it’ is going to be misinterpreted.

Pragmatic Solutions

One of my biggest concerns with a lot of SPW documents is that they almost never take into account the value of pragmatism over perfection. Perfection is not achievable (much less at an acceptable cost) while “better” usually is achievable. (Surely “better” that everyone can do is better than “perfect” that is unachievable?) To those who insist, “evil slug vendors are profit driven and always want to do the minimum,” my response is that economics rules the world and doesn’t necessarily argue for the minimum. Generally speaking, it’s more profitable to find security vulnerabilities and fix them earlier in a product release cycle than waiting until you ship six affected versions of product and now have to produce 120 patches for a single issue (or patch 120 cloud instances). Most vendors know this (or find out the hard way). Customers certainly know this and complain if they have to apply too many patches (or if their cloud service uptime is negatively impacted by a lot of patch-related downtime).

More to the point, unless you can print money, invent a time machine or perfect cloning, time, money and people are always constrained resources so using them well is a must. Doing more X means – often – doing less of Y, because you can’t add more resource you don’t have or can’t find. Worse, doing more of X required for compliance may mean doing less of the Y that actually improves security, since they are mutually exclusive as long as resources are constrained and regulations are written by (or interpreted by) the Knights Who Say Ni.

In particular, I see little evidence that people proposing SPW have done much or any economic analysis of the cost of compliance. I know the government knows how to do this kind of analysis because – for example – the US Department of Defense does resource planning that among other things looks at “how many conflicts are we prepared to fight simultaneously?” rather than, “in a perfect world with unlimited resources and cyborg soldiers, we could take on Frabistatians, the Foobarians, and open a third front combating the Little Green Men from Marsians.” How I wish that other entities – any other entity – would analyze (e.g., do a reality check) on what the impact of X is before it becomes part of a SPW.

Any SPW should include an economic analysis of impact – and look at options. Included in that analysis should be the bane of (quasi-)regulatory ambition, “unintended consequences.” There are almost always unintended consequences of SPW, even those created with good motives. One of the big ones is, if you make it too expensive for suppliers to deal with you, there will be fewer suppliers. And that means choice will decrease and cost will increase. Any SPW should explicitly ask the question, “What would matter the most, be broadly implementable and cost the least (or be the most cost effective for all parties)?”

To provide an example, the NIST Interagency Report 7622 Notional Supply Chain Risk Management Practices for Federal Information Systems (the draft requirement has, I believe, since been excised) at one time wanted the “supplier” (e.g., a vendor) to notify the acquirer (e.g., a government agency) of “all personnel changes involving maintenance.” I suspect that the intent was something to the effect that, if the acquirer (let’s say, DoD) outsources a service, and that service involves a fundamental change of venue – e.g., the maintenance for the US Department of Defense manpower system is outsourced to Hostile Foreign Country, DoD wants to be notified. However, that is not what the requirement stated. One interpretation would be that any time someone touched code who didn’t write the original code (“a personnel change involving maintenance”) that a vendor would have to notify the government. Ok, Oracle has almost 5000 products (and lots and lots of clouds), billions of lines of code, and every day there are a lot of code checkouts where someone is changing something he or she did not write. Are we supposed to tweet all that stuff? What is that going to do for the acquirer? “Kaitlyn checked out and changed code that, like, Ashley wrote, LOL, OMG!”

Figure out what you really want, and what it is worth to you to get it.

Prescriptive Minimization

With rare exceptions, non-technical* process or management standards should not tell industry how exactly to do something, if for no other reason than there is no such thing as “best practice.” There are certainly better or worse practices, but arguably no single practice that everyone does, exactly the same way, that will work equally well for everyone subject to the requirements, for any length of time. Worse, SPW diktats often stifle innovation, drive up costs (without commensurate benefit) and fall prey to the buggy whip effect (where you are specifying how to use buggy whips long after people have moved from horse-and-buggy to Model Ts - or better). Add to all these reasons the economic impact referenced above.

To provide one example, consider (draft) NIST Special Publication 800-160 Systems Security Engineering, containing a requirement that, in the event of a discovered security bug, the engineering team should conduct root cause analysis. This sounds like a Mom and Apple Pie requirement on the face of it, so what could possibly be wrong with that? A clear Best Practice, right? Well, no, not really, on grounds of pragmatism and context.

Consider a security bug that is not only high impact but for which there is an exploit circulating in the wild. For commercial software vendors, job 1 will be getting a patch into customers’ hands (or at least the hands of their customers’ system administrators) and/or patching their cloud instances, as the case may be. Protection of customers under these circumstances is initially way more important than determining causation.

Second, it doesn’t necessarily make sense to do a root cause analysis on every single security bug of every severity. What does make sense is to deep dive on the more severe bugs (e.g., high Common Vulnerability Scoring System (CVSS) Base Score bugs), because those are the ones you really want to ensure you fixed completely (and avoid in the future). You might want to ask the following as part of your analysis:

“How/when did this get into the code base?”
“What is the resulting vulnerability (how can it be exploited)?”
“Have we looked elsewhere for similar problems?”
“Have we added test cases to regression tests and other test suites (like static analysis tools) to ensure that we can automate finding other instances?”
“Have we fixed it everywhere (or everywhere that is relevant?)”and
“Have we attempted to enshrine/transfer knowledge of the severity and impact of this bug across the development organization (so everyone knows why it’s a big deal and how to avoid it in future)?”

Given scarce resources, I’d argue that root cause analysis on a CVSS 0 bug is not as important as thoroughly addressing – and in future avoiding – a CVSS 9.0 or 10.0 bug, along the lines of the above analysis. If a standard enshrines the former, it leads to suboptimal resource allocation (like spreading peanut butter over too many slices of bread). Worse, any company doing the “better” thing will get dinged as being non-standards compliant if there is a Best Practice enshrined in SPW that calls for root cause analysis of everything, regardless of severity. Perfection works against actual security improvement.

Another “best practice” I see shilled relentlessly is third party static analysis. I’ve opined on why that is not a best practice in previous blogs, but I have new reasons to avoid it like the plague it is, which is a real world example of the high cost and low utility. Recently, we were made aware that a customer of Oracle (without asking our permission, that we would not have given if asked) submitted our software to a third party that does static analysis on binaries. Where to start with how extremely bad this is? Numero uno: the customer violated their license agreement with Oracle, which alone made their actions completely unacceptable. Add to that, the report we were furnished included alleged vulnerabilities not merely in Oracle but in another product Not Made By Oracle. (Needless to say, we could neither analyze those issues nor fix them in the event they turned out to be actual vulnerabilities and really, we did not want to see alleged vulnerabilities in Someone Else’s Code. That information is extremely sensitive and should not have been given to us.) Last but far from least was the fact that – drum roll – not one of the alleged security issues the third party reported was, in fact, an actual security vulnerability. 0% accuracy: zilch, zip, nada, bubkes, a’ohe mea. Further, one of our best security leads (I’d bill him out at least $2,000 bucks an hour) wasted his very valuable time determining that there was “no there, there.”

Running a tool (if and only if you have permission to do it) is nothing; the ability to analyze the results is everything. Third parties cannot do that since they have no actual code knowledge of what they are running the tool on, especially not on a code base as big as Oracle’s is. Third party static analysis is thus only a best practice if you want to waste time and money. But it’s the vendor’s time that is being wasted (maybe that third party should reimburse us the $2K an hour our kahuna spent analyzing their errata?), and the customer’s money. And last, but really first, violating licensing terms is unacceptable business conduct.


Nobody is perfect, but with all the attention being focused on cybersecurity, it would be really helpful if attempted problem solvers writing SPW could sharpen their – I was going to say, knives, but I am not sure I mean that! – focus. Yes, a sharpened focus is what is needed. Cybersecurity is an important area. Better security is achievable, but only if we know what we are worried about, we speak the same language, we can look at relative costs and benefits, and we allow for latitude in how we get to better. We can’t do everything, but everybody can do something. Let’s do the some of the things that matter – and that won’t make us spend resources checking boxes instead of making sure nobody can break into the boxes.

· I    * I note that one reason for technical standards is, of course, interoperability. In which case, people do need to implement, say, the Secure Whateverworks Protocol (SWP) a particular way, or it won’t work with another vendor’s implementation of SWP.

For More Information

Ruthlessly self-serving announcement follows: my sister and I, writing as Maddi Davidson, are pleased to announce that we have completed our third book in the Miss-Information Technology Mystery Series, With Murder You Get Sushi. (Also, our short story “Heartfelt” will appear in Mystery Times Ten this month, published by Buddhapuss Ink.)

Apropos of nothing having to do with security, I have discovered and become totally addicted to The Palliser Novels by Anthony Trollope. Like high class soap opera, only you get classics points for reading them. (Best of all, nobody in the book is named “Kardashian.”)

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Comments ( 1 )
  • Lauren Monday, April 13, 2015

    Thanks for sharing the four P's of procurement standards and requirements. Great information!

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