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Re: Fwd: Call for input to President's Commission on Enhancing Cybersecurity

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On 07/16/2016 06:22 PM, Joy wrote:
> - - - Begin forwarded message - - -
> Date: July 15, 2016 at 3:21:32 PM EDT From: Herb Lin
> <herblin@stanford.edu> To: "'David Farber (dave@farber.net)'"
> <dave@farber.net>, ip <ip@listbox.com> Subject: Call for input to
> President's Commission on Enhancing Cybersecurity - bridging the
> trust gap between the IT community and the US government

> You may know that President Obama has established a commission to
> consider how to strengthen cybersecurity in both the public and
> private sectors while protecting privacy, ensuring public safety
> and economic and national security, fostering discovery and
> development of new technical solutions, and bolstering partnerships
> between Federal, State, and local government and the private sector
> in the development, promotion, and use of cybersecurity
> technologies, policies, and best practices.

The mission defined above is much more ambitious than it may initially
appear, because direct conflicts of interest are hard wired into it.
The "cybersecurity" buzzword embraces a spectrum of practical security
context from protecting consumer financial credentials through
shielding "secret" government databases from unauthorized access, to
preventing malicious alteration of the firmware that runs our civil
and industrial infrastructure.  Privacy is not encompassed by the term
"cybersecurity" as it is intended and understood by those who use
presently use it in a national policy context - but this can and
should change.

Network security addresses practical concerns of privacy, utility,
reliability and cost effectiveness as well as countermeasures to
stereotypical hacker threats.  The express inclusion of privacy
protection in its brief directs the Commission to deliver
recommendations directly counter to the interests of private
enterprises and government departments which presently collect,
analyze, and transfer or act on "private" information about
individuals and groups.  If economic security is taken to include
protecting the revenue streams of dominant U.S. IT vendors and their
associated armies of specialized workers in the field, either
"cybersecurity" or economic security must be sacrificed.  If national
security is taken to include protecting intelligence service access to
surveillance and sabotage targets via widely distributed security
defects in IT products and services, either "cybersecurity" or
national security must be sacrificed.

A security model can not be "just a little bit pregnant."  Every
variance or exception that permits violations of any system's
specified security protocol creates new vulnerabilities that
compromise the security of that system, usually in subtle as well as
obvious ways. Security threats are both external and internal to the
enterprise, and include hackers who want to break in for fun and/or
profit, but also:  Enterprise IT consumers who who make non-negotiable
demands for features and functions that create security
vulnerabilities; senior executives whose golfing buddies know more
about network security than the enterprise's entire IT staff; IT
vendors who are free to hide deficiencies and misrepresent their wares
under immunity from prosecution or civil liability; academics and
consultants whose personal fortunes rise and fall with the value of
vendor-specific credentials; and certified technical workforces whose
educational and occupational background is restricted to a vendor
specific context, and includes mandatory training as outside sales
reps for those same vendors.  Add to this the massive political
influence of dominant U.S. IT vendors' senior executives and major
shareholders, and our picture of an industry hard wired for security
failure is complete.  The expected end result of the complex of
counter-security factors outlined above would be smoking rubble, and
that is and apt description of prevailing network security conditions.

Pervasive "cybersecurity" failures have prompted the Executive branch
to prepare for intervention across both government and private sector
domains; in itself this is evidence that a deep systemic disorder
harmful to the National Interest has been recognized and acknowledged.
 Developing a functional model that explains why an emergency exists
is the first step toward reliably and durably ending it.  The
inclusive nature of the Commission's mandate requires it to address
"cybersecurity" in a holistic manner.  The systemic disorders listed
above are inherent in the present economic and political relationships
of parties whose inputs control IT security across all domains.

Effective solutions will be called "radical" and rightly so, as one
must change the underlying economic and political relationships that
drive the ongoing failure of "cybersecurity" to achieve meaningful
results.  Bolting layers of external reinforcement onto a broken
machine does not fix the machine, only prolongs its ability to produce
broken outputs.  Like an urban renewal project, implementing an
effective national "cybersecurity" strategy begins with a wrecking
ball.  If this is not an acceptable option, "enhanced cybersecurity"
is not a possible outcome.

> Recognizing that trust is hard to build and easy to destroy (and a
> variety of things have happened over the last 20 years have
> occurred to do the latter), one issue that has come up is the
> enormous gap of trust between the U.S. government and the
> information technology (IT) community, from which many IPers are
> drawn.  This rift is not helpful to either side, and I'd like to
> solicit input from the IP community about what you think the
> government can do or refrain from doing to help bridge that gap.

In the present context, trust has two distinct and nearly opposite
definitions:  In a political context, trust means confidence
cultivated to further a collaborative and/or manipulative agenda.  In
a network security context, trust is a controlled asset whose role is
minimized on every front and excluded where and as possible:  A
trusted actor or system is one that can break your security model.

A competent IT security strategy compartmentalizes, simplifies and
hardens the handling of protected assets.  Tools must be selected and
protocols designed on a case by case basis to enable a given
enterprise or department's necessary functions while minimizing
exposure of its assets to hostile actors.  Trust is rationed, and
dispensed only where and as the benefits of trust outweigh the risks.

As a simple example illustrating the role of trust in "cybersecurity,"
all major web browsers automatically download and execute software as
directed by any website their users visit, without the user's
knowledge or express consent.  Large families of critical security
vulnerabilities grow from this promiscuous trust model.  Many botnets
propagate themselves via this vector, which has also enabled targeted
attacks compromising "secured" assets affecting major corporations and
government agencies.  Browser makers build automatic execution of 3rd
party software into their browsers because both end users and major
commercial website operators demand it.  Vendor efforts to mitigate
this critical security threat by 'sanitizing and sandboxing' incoming
executable code can reduce but not reliably prevent high impact
security incidents arising from a fundamentally insecure trust model.

Informed end users can install tools like NoScript which prevent the
browser from downloading and executing software without the user's
express consent.  Individual websites can be whitelisted by the user,
where and as the benefits of automatically executing arbitrary
software from a given site are believed to outweigh the risks of doing
so.  In practice this trivially simple trust based security measure
has proven itself orders of magnitude more effective than a
promiscuous trust model "mitigated" by complex, failure prone defenses
against hostile code.

Bridging the trust gap between the IT community and the US government
is already a done deal, because there has never been one.  The U.S.
government funded and directed the creation of the IT industry.  As
indicated above, the existing bridges enabling public/private
partnership in IT enterprises create promiscuous trust relationships
in the face of conflicts of interest, perverse incentives and
institutional inertia all working against the objectives of
"cybersecurity."  Rather than reinforcing them, these bridges must be
locked down or removed as the first step toward enhancing

> 1 - Your best examples of things the government (and what part of
> the US government) has done to alienate the IT community
> specifically. (Or, at the very least, show how the examples you
> provide connect to the interests of the IT community.)

The U.S. government has not alienated the IT community:  It has
shielded this community from liability for fraudulent performance
claims, fed it billions of dollars of annual revenue, and given
Fortune 500 IT corporations nearly full control of government policy
affecting those same corporations.  The intimate partnership of IT
vendors and government decision makers has, however, alienated a large
segment of the public at large.  With regard to privacy concerns, IT
vendors are correctly perceived as the government's partners in
domestic mass surveillance.  The interests of the IT community are
directly served by the government's nearly absolute tolerance for
commercial mass surveillance, inherently insecure products and
protocols, forced obsolescence strategies and abusive marketing
practices - all of which are routinely implemented by major IT vendors
to reduce costs and/or enhance revenues.

The current condition of gross insecurity across private and State
owned IT assets is a product of the dominant role of vendors who are
richly rewarded for exploiting the technological ignorance of private
and public sector decision makers.  The cumulative cost of unstable,
insecure IT infrastructure supplied and serviced by parasitic vendors
greatly exceeds the short term costs of replacement with stable,
security oriented infrastructure; but perverse incentives and
conflicts of interest assure that no such course can be taken absent
dynamic and determined public sector leadership.

> 2 - Things that the U.S. government could realistically do in the
> short and medium term (i.e., 0-10 year time frame) that would help
> bridge the trust gap.  If your answer is "Don't do dumb things!",
> it would be better and more useful to provide *examples* of what
> not to do.

Revoke software vendors' blanket immunity from prosecution for
consumer fraud and from liability for damage caused by failure to
control product defects.  Where there is no accountability, there is
no motivation to spend money on security and no rational basis for
consumer trust.  The infallible invisible hand of the Free Market can
not produce security, quality or innovation where the State grants
special immunity from prosecution and civil liability to privileged

Mandate security evaluations based on performance and design metrics
for all software (and firmware) purchased for use by government
agencies and departments.  These evaluations must include examination
of the specific product offerings under consideration, and the
bidder's historical security track record across all products.  Total
cost of ownership calculations for IT assets must include estimated
costs of potential security failures, and projected costs of recovery
from same, proportionally adjusted to reflect the relative security
performance of each competing bidder's products.  This could be
facilitated by the establishment of a transparent, accountable Federal
activity that collects relevant data and produces reports in a
standardized format consistent with government procurement process.

Mandate reporting of security incidents by every government activity,
and every commercial enterprise with a State or Federal tax ID, where
financial losses and costs of remediation and recovery from the
incident exceed $5,000.00.  Require reporting of the category of
failure, specific software tools that presented the vulnerabilities
exploited, direct losses incurred, and the costs of remedial and
recovery measures taken.  Specify that aggregate data from these
reports be made available to the public on at least a quarterly basis.

Direct the Federal Communication Commission to conduct and annually
review studies on the privacy impacts, positive and negative, of
deployed and proposed network communication protocols and Standards,
publicly report their findings, and solicit public comments in a
transparent process.  Mandate that all reports reference IETF RFC
6973, Privacy Considerations, as guidance in identifying, naming and
evaluating adverse and beneficial privacy impacts of deployed and
proposed network communication protocols and architectures.

> 3 - Things that the U.S. government could realistically do in the
> longer term to do the same.

See above.  A durable commitment of all necessary resources to assure
that the measures suggested in response to query 2 are effectively
implemented would create and sustain rational, constrained trust
relationships affecting all those aspects of "cybersecurity" which are
properly the government's business.

The requirement that recommendations be "realistic" is regrettable.
"Practicable" would have been better language.  A realistic proposal
might be considered as one that will not provoke a do-or-die defense
of the status quo from dominant IT vendors, U.S. intelligence
activities, and others whose bread and butter is "cyber insecurity."

A practicable proposal would be one that is within the scope of public
policy authorities and industry capabilities:  Vendors who assert that
requirements are "impossible" or simply refuse to comply will be
replaced by vendors who are ready to step forward and meet any
challenges presented.  Solutions to many of today's most serious and
widespread network security failures are already avaialbe as off the
shelf products from vendors with excellent security track records.
The proposals presented under query 3 above may not be considered
reasonable by dominant industry stakeholders, but they are
practicable, and these or materially similar policy initiatives are
necessary if the President is serious about getting the results he has
asked for.

Steve Kinney
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