Policy fads and policy failures

In cyber security, user awareness, education and training have long gone past their Use By Date. We have technological problems that need technological fixes, yet governments and businesses remain averse to investing in real security. Instead, the long standing management fad is to ‘audit ourselves’ out of trouble, and to over-play user awareness as a security measure when the systems we make them use are inherently insecure.

It’s a massive systemic failure in the security profession.

We see a policy and compliance fixation everywhere. The dominant philosophy in security is obsessed with process. The international information security standard ISO 27001 is a management system standard; it has almost nothing to say universally about security technology. Instead the focus is on documentation and audit. Box ticking. It’s intellectually a carbon-copy of the ISO 9001 quality management standard, and we all know the limitations of that.

Or do we? Remember that those who don’t know the lessons of history are condemned to repeat it. I urge all infosec practitioners to read this decade old article: Is ISO 9000 really a standard? — it should ring some bells.

Education, policy and process are almost totally useless in fighting ID theft. Consider this: those CD ROMs with 25,000,000 financial records, lost in the mail by British civil servants in 2007 were valued at 1.5 billion pounds, using the going rate on the stolen identity black market. With stolen data being so immensely valuable, just how is security policy ever going to stop insiders cashing in on such treasure?

In another case, after data was lost by the Australian Tax Office, there was earnest criticism that the data should have been encrypted. But so what if it was? What common encryption method could not be cracked by organised crime if there was millions and millions of dollars worth of value to be gained?

The best example of process and policy-dominated security is probably the Payment Card Industry Data Security Standard PCI-DSS. The effectiveness of PCI-DSS and its onerous compliance regime was considered by a US Homeland Security Congressional Committee in March 2009. In hearings, the National Retail Federation submitted that “PCI has been plagued by poor execution … The PCI guidelines are onerous, confusing, and are constantly changing”. They noted the irony that “the credit card companies’ rules require merchants to store credit card data that many retailers do not want to keep” (emphasis in original). The chair committee remarked that “The essential flaw with the PCI Standard is that it allows companies to check boxes, but not necessarily be secure. Compliance does not equal security. We have to get beyond check box security.”

To really stop ID theft, we need proper technological preventative measures, not more policies and feel-good audits.

The near exclusive emphasis on user education and awareness is a subtle form of blame shifting. It is simply beyond the capacity of regular users to tell pharming sites from real sites, or even to spot all phishing e-mails. What about the feasibility of training people to “shop safely” online? It’s a flimsy proposition, considering that the biggest cases of credit card theft have occurred at backend databases of department store chains and payments processors. Most stolen card details in circulation probably originate from regular in-store Card Present transactions, and not from Internet sites. The lesson is even if you never ever shop online, you can have your card details stolen and abused behind your back. All the breathless advice about looking out for the padlock is moot.

In other walks of life we don’t put all the onus on user education. Think about car safety. Yes good driving practices are important, but the major focus is on legislated standards for automotive technology, and enforceable road rules. In contrast, Internet security is dominated by a wild west, everyone-for-themselves mentality, leading to a confusing patchwork of security gizmos, proprietary standards and no common benchmarks.