Re: ICSA - Certified Sites and Criteria Issues

From: David Kennedy CISSP (dmkennedyat_private)
Date: Fri May 28 1999 - 13:39:03 PDT

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    	I'm taking it upon myself to respond for Jon who's busy trying to
    have a life outside the office.  As he did, I'm going to try to steer
    clear of a specific discussion of any of our customers.
    	We thank the open review process of the total crypto community for
    bringing this to our attention.   We will include this discussion in
    our ongoing process to maintain the TruSecure criteria.
    	I'd like to restate what I feel is the most pertinent criterion that
    bears on this issue:  the criterion requires encryption and protocols
    acceptable to both the host and the client.  As a practical matter,
    for web activity this is either 40-bit SSL or 128-bit SSL.  The
    TruSecure customers have the flexibility to choose, and their
    customers, in turn, decide if this is "acceptable."
    	Clearly, most of the readers of these lists regard 128-bit SSL as the
    minimum they would find acceptable.  However I think those same
    readers would acknowledge that the majority of users on the Internet
    worldwide today are using a 40-bit version of the popular browsers.  A
    business has every right to decide if 40-bit SSL is the level of
    security they feel is appropriate for the information they are
    processing.
    	A TruSecure customer may make a business decision that 40-bit SSL is
    "acceptable" for the communication of data from their hosts to their
    clients.  Once this decision is made, they may configure their systems
    for 40-bit only.
    	It should be clear from Jon's previous message that, in the abstract,
    128-bit SSL is preferable to 40-bit SSL.  However, 40-bit SSL for all
    it's faults, protects data in transit from the client to the host from
    all but a targeted attack by an experienced, well-resourced adversary.
     40-bit SSL provides superior security than the majority of meatspace
    exchanges of sensitive information.
    
    At 07:53 PM 5/27/99 -0400, David Schwartz wrote:
    >
    >	So does ICSA certification mean simply that a company has met its
    own
    >requirements? (As opposed to some set of objectively validated or
    >ICSA-imposed requirements?)
    
    	Certification requires compliance with our criteria.  The best web
    page we have describing this is: http://www.trusecure.net/process.html
     If you want the nitty gritty details, browse to
    http://www.trusecure.net/
    and either go to the library or click the "contact us" link.
    	ICSA helps customers address risks across multiple categories
    (physical, hacking, malicious code, spoofing, eavesdropping, lack of
    knowledge/awareness, lack of trust, DoS, privacy-user by site & data
    subject, lack of interoperability).  We developed a methodology to
    focus on high risk/cost categories and follow this methodology with
    our customers.  When addressing the issue of privacy, ICSA approaches
    the matter by addressing the risk of capturing customer information
    across the wire and as it resides on the customers server.  We do
    require the use of encryption but choose to let the customer to decide
    the level based on the assets they are protecting, the impact to their
    business, and the fact that the real concern is the data residing on
    the server un-encrypted.  ICSA therefore works with our customers to
    set up multiple layers of synergistic controls that not only address
    the use of encryption but also those mentioned above.
    	We rely on addressing our customers' issues not only from a
    technology perspective, but from a business level one as well.  When
    deploying security, ICSA will always address how technology impacts
    our customers operations and costs.
    
    At 07:31 PM 5/27/99 -0400, Adam Shostack wrote:
    >Do you require certified sites post their security policy?  If not,
    >how do I know that the policy doesn't explicitly accept the presense
    >of phf in /cgi-bin?  Would it be possible to have that in my policy
    >and still get certified, if I have good business reasons for putting
    >it in place?
    >
    
    	For the purposes of site certification we would not certify a site
    with phf in the cgi-bin directory.  Our criteria do restrict this.
    However, we have customers who have purchased TruSecure but have "good
    business reasons" for ignoring or violating one or more of our
    criteria.  ICSA has a process to review these occurrences and have
    withheld certification from some of these customers.  Indeed, we have
    customers who are quite satisfied with their TruSecure purchase
    without achieving certification.  Without turning into a
    sales/marketing droid, we try to emphasize TruSecure as a process to
    provide acceptable security to the customer; many customers are
    satisfied without completing certification and know this before their
    purchase.
    
    >This flap may be a result of certifying compliance to policy, but the
    >relying parties on your mark should not be expected to be able to
    read
    >and understand those policies; they should be able to rely on your
    >mark to say that the policies make sense.  Incidentally, do you
    >require sites to post these policies to which you certify compliance?
    >
    
    	Certified sites must post a privacy and user data security policy as
    part of our criteria.  We do not require the site to post their
    security policy.  Most enterprises would be reluctant to post an
    un-santitized version of their security policies which opens the
    question of how much sanitization is necessary or desirable.  I don't
    believe it would be wise to require they post the nitty gritty details
    of their policies.  One would not want details such as these widely
    known:
    
    	Inbound telnet is blocked except from IP xxx.xxx.xxx.xxx to
    yyy.yyy.yyy.yyy which is permitted so Y Inc can review progress
    reports on Project Z.
    	Employees assigned to our office in Sri Lanka will use PPTP to host
    at zzz.zzz.zzz.zzz to access the company intranet.
    
    At 07:36 PM 5/27/99 -0400, Russ wrote:
    >However, the bottom line is that;
    >
    >- They are *NOT* employing "sophisticated encryption", they're
    employing
    >the least sophisticated deployable.
    >
    
    	I can't respond to this directly.
    
    >- They also say ICSA "examined every aspect of our security
    >precautions", but in fact, you only examined those aspects defined in
    >their policies.
    
    	For any customer, we examine every aspect defined by *our* criteria,
    which includes examining their security policies and implementations,
    but these two aspects are but a handful of the 200+ criteria we
    include in TruSecure.
    
    >
    >- They also claim that because of your certification, their customers
    >"know ConsumerInfo.Com's security measures are state-of-the-art" when
    in
    >fact their *NOT*.
    
    This issue is with the semantics on a page not maintained by ICSA.
    
    >
    >I will not, at this time, question the integrity of ICSA. Nor will I
    >suggest that ConsumerInfo.Com is out and out lying.
    >
    >I will, however, suggest that ICSA is tacitly allowing
    ConsumerInfo.Com
    >to mislead their customers via the ICSA Web Certification approval.
    By
    >ICSA not being permitted, by NDA, to discuss certification they have
    >performed, it renders, IMNSHO, the certification itself *worthless*.
    It
    >would appear that ConsumerInfo.Com has been allowed to say anything
    they
    >want about their work with ICSA and, by NDA, ICSA cannot rebuke it.
    >
    
    	The way this paragraph is constructed makes it impossible to respond
    to it.  We would like to respond, and explain how certification is not
    as you say, "worthless," but to do so would be to reveal confidential
    information about a customer.
    
    At 07:36 PM 5/27/99 -0400, Lucky Green wrote:
    >
    >Now I am really getting worried. From your post it is clear that you,
    a
    >representative of ICSA, are unaware that by enabling 128 bit TLS/SSL
    on a
    >server you by no means prevent users limited to 40 bit crypto from
    accessing
    >it.
    >
    
    	Incorrect, we understand this fact.
    	Again, the criteria require encryption and protocols acceptable to
    both the host and the client.  Popular browsers provide the capability
    for users to click on an icon and determine the encryption being used,
    if any.  Undoubtedly that's how this thread started.
    
    
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    Regards,
    David Kennedy CISSP
    Director of Research Services, ICSA Inc. http://www.icsa.net
    
    Using encryption on the Internet is the equivalent of arranging
    an armored car to deliver credit-card information from someone
    living in a cardboard box to someone living on a park bench.
    		      Gene Spafford
    



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