Risk
11/19/2009
11:15 AM
Connect Directly
LinkedIn
Google+
Twitter
RSS
E-Mail
50%
50%

Lessons Learned From PCI Compliance

Assessors reveal mistakes companies make with data security standard.

Whether you think PCI is a useful standard that makes our credit card data safer or a credit card industry whitewash that merely creates the illusion of security, PCI compliance is a fact of life.

As part of PCI compliance, companies that process a high volume of credit card transactions must submit to an annual assessment by a qualified security assessor, or QSA. For example, Visa requires it of merchants that process 6 million or more transactions. Assessors work for third-party organizations and generally visit companies to examine their processes and determine whether they comply with PCI rules.

InformationWeek Reports

To help companies get ready for a an evaluation, we asked QSAs to describe common problems they encounter when working with IT groups on PCI compliance. What follows are five best practices to help companies better prepare for an assessment and maintain compliance.

1. Know Where Data Lives

First off, you must know how credit card data flows through your system, where the data resides in the enterprise, and who has access to it. Assessors ask for this information at the outset of an assessment because it determines the scope of the project. They aren't there to review your entire security infrastructure, just the systems that collect, process, transport, and store credit card data. A surprising number of companies don't have a good grasp of this information. "It's common for a client to completely miss a particular data flow and have no idea that credit card data is being forked off to system X, Y, or Z," says a QSA at Neohapsis, who asked to remain anonymous.

Companies express an "extreme amount of frustration" over the amount of effort they have to put in to put the full picture together, says Ted Keniston, a QSA and managing consultant with the global compliances group at Trustwave. "We should be validating this information, not determining it."

Having a complete picture of credit card data isn't just a courtesy to your assessor; it also affects your ability to protect customer information, because you can't secure what you don't know about.

2. PCI Is A Moving Target

Let's say your assessor has just stamped you "compliant." You breathe a sigh of relief. The PCI assessment is annual, so you don't have to worry about it for another 12 months, right? Not so.

PCI compliance is only valid and only applies to the state of the network and systems at the time of the assessment. The moment you make changes to systems that fall under the scope of PCI, your compliance status is in question.

DIG DEEPER
PCI And The Circle Of Blame
PCI is a flawed exercise in protecting credit data. The requirements are sound, but complying is costly, creating an incentive to seek the least expensive path to compliance. The process can be manipulated so merchants seem compliant without actually making their data more secure. And credit card issuers have little reason to make any changes. It's a process in need of improvement.

Of course, no network or computer system remains unchanged, so companies must account for how those changes will affect compliance. All of the controls and processes you put in place to demonstrate compliance at the assessment must be carried forward.

"Change management, log management, system configuration changes--it all has to adhere to PCI requirements," says Trustwave's Keniston.

A related issue is that PCI rules are intended to be adopted as part of ongoing operations. Compliance isn't an annual flu shot that you only think about once a year. It's more like exercise--it has to be done regularly.

For example, PCI requires companies to review firewall rulesets, but this can be a tedious and time-consuming task, easily put aside by busy IT pros. To prevent this from falling by the wayside, one QSA suggests creating scheduled tasks that get assigned to administrators as part of their regular workflow.

Many companies try to bolt on PCI compliance instead of embedding the practices dictated by the standards into their everyday operations. Often they don't want to hear about compliance when developing projects, particularly revenue-generating ones, because any delay in deployment means a delay in income, says the Neohapsis QSA. "They wait until the audit to find out what they need to change, and the cost is always higher to fix it on the back end instead of building it right from the get-go."

If your organization has incorporated PCI requirements into daily operations, be sure you document it so you can get credit. A lot of companies do what they're supposed to for PCI, "but they've never put it in a policy or have anything formal that says 'This is what we do,'" says Trustwave's Keniston.

Previous
1 of 2
Next
Comment  | 
Print  | 
More Insights
Register for Dark Reading Newsletters
White Papers
Flash Poll
Current Issue
Cartoon
Video
Slideshows
Twitter Feed
Dark Reading - Bug Report
Bug Report
Enterprise Vulnerabilities
From DHS/US-CERT's National Vulnerability Database
CVE-2014-0972
Published: 2014-08-01
The kgsl graphics driver for the Linux kernel 3.x, as used in Qualcomm Innovation Center (QuIC) Android contributions for MSM devices and other products, does not properly prevent write access to IOMMU context registers, which allows local users to select a custom page table, and consequently write ...

CVE-2014-2627
Published: 2014-08-01
Unspecified vulnerability in HP NonStop NetBatch G06.14 through G06.32.01, H06 through H06.28, and J06 through J06.17.01 allows remote authenticated users to gain privileges for NetBatch job execution via unknown vectors.

CVE-2014-3009
Published: 2014-08-01
The GDS component in IBM InfoSphere Master Data Management - Collaborative Edition 10.0 through 11.0 and InfoSphere Master Data Management Server for Product Information Management 9.0 and 9.1 does not properly handle FRAME elements, which makes it easier for remote authenticated users to conduct ph...

CVE-2014-3302
Published: 2014-08-01
user.php in Cisco WebEx Meetings Server 1.5(.1.131) and earlier does not properly implement the token timer for authenticated encryption, which allows remote attackers to obtain sensitive information via a crafted URL, aka Bug ID CSCuj81708.

CVE-2014-3534
Published: 2014-08-01
arch/s390/kernel/ptrace.c in the Linux kernel before 3.15.8 on the s390 platform does not properly restrict address-space control operations in PTRACE_POKEUSR_AREA requests, which allows local users to obtain read and write access to kernel memory locations, and consequently gain privileges, via a c...

Best of the Web
Dark Reading Radio