RE: I-0451: When To Use IFF/IFC And AFF/AFC

["Michelle A. Ruppel" <maruppel@saffiresys.com>]

I have the following comments on this proposal for formal guidance.

General Comment:
1. Network devices have used IFF.1 / IFC.1 to define the data flow through
the device since the beginning of the CC.
The 4 validated Firewall Protection Profiles do not comply with this
interpretation. 
Since this can and probably will be confusing to many individuals, consider
addressing this discrepancy in this Guidance Interpretation.
The Guidance provided removes the ability to control/mediate data flow
through network devices. If this guidance is
released, it needs to provide an alternative for controlling/mediating data
flow through network devices.

Consider allowing IFF.1 / IFC.1 to remain to be interpreted as it has
historically and suggest that IFF.2-6 and IFC.2 to apply to
the guidance since these requirements are where lattices and illicit
information flows enter the requirements.

Statement

1.  ". IFF/IFC should be used when the intent is to control the flow of
information."

This statement, depending on one's background and interpretation, allows for
IFF/IFC to be used for applications such as firewalls, routers, etc.
Based on the rest of the Guidance, I do not believe this is what was
intended.

2. "Information flow control is based on some fundamental characteristic of
the information (not the container), and may not involve an active subject."

The characteristic of the information is usually stored in or with the
container, so one could interpret that the fundamental characteristic is
also
on the container.  If my interpretation of what is meant here is correct, I
suggest rewording this sentence so the intent is not lost.
Consider something similar to following:
"Information flow control is based on some fundamental, static
characteristic of the information (which may be stored in or with the
container but will always
be associated with/linked to the information as it moves through the TSF),
and may not involve an active subject. Only a privileged user can modify
the characteristic associated with the information." Or is it a permanent
characteristic??

3. "Information flow policies dictate whether information with a particular
characteristic can move from one controlled entity to another."

As a standalone sentence, this would allow information flow policies to be
used for applications such as firewalls, routers, etc. For example,
an owner or originating IP address could be a particular characteristic. 
However, this is not the intent, so you may want to consider rewording to
something like :
"Information flow policies dictate whether information with a static
characteristic can move from one controlled entity to another." Or is it a
permanent characteristic??

Support Section:

4. Last sentence: "The type of policy should be chosen based on the
fundamental type of control: is it subject access to an object, or is it
based on characteristics of the information."

Depending on your interpretation, neither of these choices apply to network
devices/applications such as firewalls, routers, etc. They can dictate what
information can flow through the appliance with no consideration of the
subject accessing an object. That decision is made on the originating system
or the destination system; neither subject or object.

Michelle A. Ruppel
Saffire Systems
P.O. Box 11154
Champaign, IL  61826
217-359-7763   Fax:  217-359-8753


-----Original Message-----
From: cc-cmt@nist.gov [mailto:cc-cmt@nist.gov] On Behalf Of NIAP
Interpretations Board
Sent: Thursday, July 31, 2003 9:51 PM
To: Multiple recipients of list
Subject: Re: I-0451: When To Use IFF/IFC And AFF/AFC



  The following is a proposal for formal guidance related to the  Common
  Criteria and ancillary documents. It is being posted in accordance with
  the procedures of the IWG.

  Comments on this proposal are welcomed and should be posted to this
  transaction chain.  If any party wishes to post a comment anonymously,
  the comment should be mailed to cc-cmt@nist.gov in a form suitable for
  posting.  All comments should be posted no later than Tuesday, October
  28, 2003.


                      CCITSE/CEM  GUIDANCE (PROPOSED)


     _________________________________________________________________

                    I-0451: When To Use IFF/IFC And AFF/AFC
     _________________________________________________________________

TYPE:                 Guidance
NUMBER:               I-0451
STATUS:               Ready for External Repost after Interpretations Board
                      Rework/Review

TITLE:                When To Use IFF/IFC And AFF/AFC
PREVIOUS POSTING:      [cc-cmt 00357]
COMMENTS DUE BY:      Tuesday, October 28, 2003 to cc-cmt@nist.gov

SOURCE REFERENCE:     CC v2.1 Part 2 Subclause 6.1 FDP_ACC
                      CC v2.1 Part 2 Subclause 6.2 FDP_ACF
                      CC v2.1 Part 2 Subclause 6.5 FDP_IFC
                      CC v2.1 Part 2 Subclause 6.6 FDP_IFF
RELATED TO:           <None>

ISSUE:

   When is it appropriate to use IFF/IFC or ACC/ACF? In particular, for
   an environment where there is an externally defined policy and no
   attributes on objects, should IFF/IFC be used?

STATEMENT

   ACC/ACF should be used when the intent is to control access to an
   object; IFF/IFC should be used when the intent is to control the flow
   of information.

   Access to an object means that there is a set of rules that define
   whether some entity (a "subject") may have a particular form of access
   to a data container (an "object") for some particular type of
   operation. There are no controls based on the information itself; that
   is: if the subject is permitted to write the object, it may write any
   data into the object; similarly, if a subject is permitted to read an
   object, it can do whatever it wishes with the data it has read.

   Information flow control is based on some fundamental characteristic
   of the information (not the container), and may not involve an active
   subject. Information flow policies dictate whether information with a
   particular characteristic can move from one controlled entity to
   another.

SUPPORT:

   When the Common Criteria was first written, the goal on the functional
   side was to capture the policies that were present in the previous
   criteria that served as inspiration. In the case of the Trusted
   Computer System Evaluation Criteria, this was Discretionary Access
   Control (DAC) and Mandatory Access Control (MAC). However, at this
   time, there was an effort not to use terms that brought with them
   specific connotations--hence, many TCSEC terms were not used in the
   CC.

   While the TCSEC separated controls based upon who was allowed to make
   changes (discretionary verses mandatory), the CC has separated
   controls based upon the type of control. Since IFF/IFC type controls
   were often non-discretionary and ACF/ACC were often discretionary the
   confusion arose that this was always the case.

   Access controls (ACF/ACC) may be used to model what in the
   TCSEC-paradigm was called Discretionary Access Control, but this is
   not their sole use. They could also be used to implement Role-Based
   Access Controls, as well as a variety of other controls. The key
   characteristic is that the controls are based on the object containing
   the information: they address the fundamental question of whether a
   particular subject can access a particular object. Note that this is
   independent of the actual implementation: it could be an access
   control list on an object, but it could also be a permitted access
   list on a subject, or some fixed rule set stored completely
   independently of either subject or object.

   Information flow controls (IFF/IFC) may be used to model what in the
   TCSEC-paradigm was called Mandatory Access Control (more properly,
   non-Discetionary Access Control, although even that is a misnomer),
   but that is not their sole use. The key characteristic is that the
   controls are based on a characteristic of the information, such as a
   sensitivity label, the quality of the data, or the source of the data.
   More importantly, the characteristic stays with the data as it moves
   through the TSF, and serves to provide the basis for the controls.
   Subjects need not be involved in this flow, as might happen in a
   network device that services to connect two ports.

   In determining which policy to use in writing a security target or
   profile, it is extremely important not to let the actual or planned
   implementation affect the choice of policy. The type of policy should
   be chosen based on the fundamental type of control: is it subject
   access to an object, or is it based on characteristics of the
   information.