Paul,

I am not suggesting that because 17799 is not prescriptive to period
that we should not define a reasonable period.

The fact that the standard is not prescriptive doesn't mean it shouldn't
be. If you aggregate, archive, but monitor only over a ridiculously long
period or do it with underqualified resources, then you are only
"playing the game" to the letter of rule, not the spirit of the
utilitarian ethic that created it.

Compliance is often independent of effective safeguards. I am actually
pointing out the fact that compliance does not manage any risk but the
risks of being non-compliant, and that is regulation specific. Doing
something useful should be mappable to all reasonable regulations.

I personally like the pragmatic and prescriptive-where-necessary nature
of PCI DSS for setting security objectives. They have to be, because
people need to USE it TODAY.

"A good plan executed today is better than a perfect plan executed at
some indefinite point in the future." - Patton.

Big three or not, the organization performing the audit are only as good
as the subcontractors they use to perform activity.

W
--
Wynn Fenwick, GCIH, GCIA, ITIL
Chief Techincal Architect, Managed Security Services
CGI ISMC

-----Original Message-----
From: Paul Melson [mailto:pmelson (at) gmail (dot) com [email concealed]]
Sent: Wednesday, May 30, 2007 5:26 PM
To: Fenwick, Wynn; loganalysis (at) loganalysis (dot) org [email concealed]
Subject: RE: [logs] SIM solution - Objectives ? (Firewall logging)

> If you look at ISO 17799 for log monitoring (where a lot of things
> like
COSO, CoBIT, and )they are not
> prescriptive on the period of reconciliation.
>
> ISO17799-s10.10.2 (this could be old) calls for the creation of
> procedures
to monitor system use, and
> review of the results of this monitoring shall happen regularly,
including:
> * Authorized access,
> * Privileged operations,
> * Unauthorized access attempts,
> * System alerts or failures, and
> * Changes to, or attempts to change, system security settings and
controls.
>
> And yes, unless you wash the feet of the auditors after they step over

> the
palm branches laid before
> them, "good enough" should suffice.

I have to disagree and say that BS/ISO 17799 requires time frames
(SLA's/OLA's) for both monitoring and review to take place and that a
response to any exceptions be initiated. This is covered in 8.1.3 in
the context of incident response and investigation. If you go the
CoBIT/ITIL route, you will have to build additional controls around
those time frames to prove that you're performing the review and the
response and that you're doing both within the windows that you say you
are. And at least where I work, both our internal auditors and our
third-party auditors (from a Big 3
firm) ask for this proof.

So, can you build something that is brainlessly 'compliant' using a
rigidly literal interpretation of a standard combined with very weak
internal P&P documents? Of course. But it's just teaching to the test.
You're not accomplishing anything. You're doing work solely to make
auditors happy.
At that point your cart is so far out ahead that your horse can't see it
anymore.

PaulM

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