3 Themes For Implementing PCI DSS 3.0 For SMBs
How the new PCI DSS v3.0 requirements affect the scope of cardholder data systems
2013 was not only a year of multiple major breaches exposing cardholder data (CHD) but also a year in which the Payment Card Industry Security Standards Council (PCI SSC) released the next major revision to the Payment Card Industry Data Security Standard: Version 3.0. PCI DSS v3.0 changes are largely aimed at misinterpretations and misapplications of requirements meant to reduce the risk of such attacks.
There are some "evolving requirements" (read: new requirements) in this new version, but mostly version 3.0 addresses a general lack of awareness and appropriate implementation of existing requirements. Small and medium businesses implementing PCI DSS typically do not require a Qualified Security Assessor (QSA) and either implement these requirements of their own or with the help of a security consultant. This series of blogs is aimed at those planning their 2014 PCI DSS strategy with 3 distinct and important themes found in PCI DSS 3.0.
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PCI DSS 3.0 for SMBs Theme 1: Scope
The cardholder data environment (CDE) comprises all system components that a) store, process, or transmit CHD, b) any component that is directly attached to those systems, or c) any component that supports those systems. Element "a)" of the above definition has been well understood but proper segmentation of connected systems is often overlooked (element "b)") and supporting systems such as update servers and authentication support have been erroneously left out of the PCI DSS scope in many SMB PCI DSS scoping diagrams.
The result of an inaccurate PCI DSS scope is the misapplication of requirements, a non-compliant business, and a more susceptible environment. Understanding such misapplication of requirements is widespread; the PCI SSC specifically strengthened the guidance and requirements to address this. The following revisions to PCI DSS address the CHD scope issue:
Current Network Diagram – Really! [Requirement 1.1.2 – Clarification; Requirement 1.1.3 - New]
The Council went out of its way to explain that not only do you need a current network diagram with all connections to CHD but also one that identifies all connections between the cardholder data environment (CDE) and all other networks. This is an important exercise in determining the scope of your CDE and the applicability of PCI DSS requirements to your network components.
Inventory of System Components [Requirement 2.4 – New; Requirement 11.1.1 – New]
There is a new requirement to maintain a formal inventory of the system components within the CDE. The reason for this requirement is to ensure that configuration standards are applied to all CDE components. In many SMBs the inventory process can be worked in with the network diagram development, in more complex systems automated inventory process would be advisable. Another new requirement states that organizations must maintain an inventory of authorized wireless access points (including the business justification).
Penetration Testing – Verify Proper Segmentation [Requirement 11.3 – New; Requirement 11.3.4 - New]
There is a new requirement for a penetration testing methodology that (among other things) includes the testing of the segmentation and scope-reduction controls. Furthermore, a specific new requirement was created for annual penetration testing to verify that segmentation methods are operational and effective in isolating CDE system components from those components deemed out-of-scope.
Determine and Reduce your Scope Now.
The PCI DSS v3.0 standards are now in effect and organizations have until the end of the year to become compliant. Organizations have adequate time to address these new requirements but determining the proper scope of the CDE (and taking steps to reduce it) is the first step.
Doug Landoll CEO of Lantego Security, a firm specializing in assisting organizations with information security compliance (HIPAA, PCI, FISMA) and can be reached at email@example.com.