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    <title>ClearNet Security: The VA and Bureaucracy</title>
    <link>http://blog.clearnetsec.com/articles/2006/06/09/the-va-and-bureaucracy</link>
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      <title>The VA and Bureaucracy</title>
      <description>&lt;img src="http://www.clearnetsec.com/roller/resources/cns/car_wreck-300px.jpg" align="right" /&gt;
&lt;p&gt;
So it has been awhile since I blogged.  Sorry!  So anyways I have been following the security breach that happened to the &lt;a href="http://www.va.gov"&gt;Veterans Affairs&lt;/a&gt; (VA) with interest.  For those of that do not know, basically a VA worker had been taking veterans data like SSN and name etc, home so that he could work on his project from home.  What happened was his laptop with USB drive got stolen from his house and the VA data went with it.  No one knows what if anything happened to the data but it does leave millions of veterans open to identity theft.  More info &lt;a href="http://www.cnn.com/2006/US/06/03/va.theft.ap/"&gt;here&lt;/a&gt;.
&lt;/p&gt;
&lt;p&gt;
This is near and dear to my heart as it was one of the first projects that Tate and I worked on.  The project was at the time the largest &lt;a href="http://csrc.nist.gov/sec-cert/ca-process.html"&gt;Certification and Accreditation&lt;/a&gt; (C&amp;A) process for the federal government was happening at the VA.  Tate and I jumped onto a contract with a company that had head count and we were off to Virginia for training.  Now for those of you that do not know, the C&amp;A process is very large and detailed.  It is created and kept by the &lt;a href="http://www.nist.gov"&gt;National Institute of Science and Technology&lt;/a&gt; (NIST) and is the process all federal agencies need to follow to be compliant.  The documents themselves are actually really well written and freely &lt;a href="http://csrc.nist.gov/publications/nistpubs/index.html"&gt;available&lt;/a&gt;.  Basically the C&amp;A process is summed up as this:  develop a policy, test against it, determine risk points, and then remediation plans.  The certification part is where the auditors, audit against the policy and the standards set by the C&amp;A documents.  The accreditation part is where the big hunchos of the agency either accept the risk and keep their IT going or stop it until the risk is remediated.  This process was what we were "thinking" we were getting into.  At this point we did not have C&amp;A experience so this was worth it for us.
&lt;/p&gt;
&lt;p&gt;
Ok.... so we get to Virginia and start what we thought was going to be some hard security work.  In fact the company we were working under thought that our skill sets might not be up to par enough....  We had to go to a meeting with all the auditors and the VA staff where they were going to let us in on the work involved and this is where we had our first exasperating moment on this project.  The main person involved on the VA side stands up and tells us this is the biggest C&amp;A process ever and blah, blah......Oh yeah, no one other than VA personnel is able to touch ANY computer either physically or virtually!  Wait a sec!  I still remember the whole crowd of 200 or so auditors all collectively looking around and I think some people in the back row made a run for it at this point.  Everyone was thinking exactly what you are thinking at this moment, how can you test "technical controls" without actually testing...  Well they came up with the answer, which was to pair us up with our very own set of VA hands, still attached to a VA employee at each site we visit.  Yup, now instead of us actually typing and testing a computer we were supposed to relay commands to a VA staff person and they would type it in!  Sweet, I can give my carpal tunnel a rest and set my jaw wagging.  I can just see it now, "Oh look, it looks like this computer has some malware. Click here, load this tool, select this hex field and check the registry....NO NOT THAT KEY!  Run!"
&lt;/p&gt;
&lt;p&gt;
Right about this time the second bomb shell went off....  The guy up front promptly says that all test results we collect are to be given to the VA.  This makes sense as it is their computers and they are entitled to our analyzed results right?  Wrong!  The guy corrects himself and says that the results are not to be analyzed by the auditors but by VA personnel.  Hmm...so at this point I am not touching a computer nor am I analyzing the results for risk or what is wrong.  Something seems very broken about this process at this point.
&lt;/p&gt;
&lt;p&gt;
In the next part I will explain the next day and our first site experience.  In reading this I am sure you are now not surprised to hear about data breaches and lameness on the part of the VA.  After all they pretty much subverted the C&amp;A process to insure they pass.
&lt;/p&gt;

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      <pubDate>Fri, 09 Jun 2006 00:52:00 -0600</pubDate>
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      <author>Cory Stoker</author>
      <link>http://blog.clearnetsec.com/articles/2006/06/09/the-va-and-bureaucracy</link>
      <category>Veterans Affairs</category>
      <category>VA</category>
      <category>security</category>
      <category>C and A</category>
      <category>Certification</category>
      <category>Accreditation</category>
      <category>Audit</category>
      <category>Cory Stoker</category>
      <category>ClearNet Security</category>
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