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Target, PCI Auditor Trustwave Sued By Banks
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AccessServices
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AccessServices,
User Rank: Apprentice
3/27/2014 | 6:49:54 AM
Compliance Does Not Mean Hack-Proof
I like PCI compliance.  It is a great fundamental step forard in security.  There is noting that says if you are compliant, you will not be breached.  Every company is different.  PCI DSS 3.0 12.2 says that companies have to implement a risk-assessment program.  Here is where the rubber really meets the road with security.  Each company needs to evaluate its own risks and respond.  I would recommend to Target and all other retailers that they demand that the card merchants provide boxes to process the card data so the retail network never sees the unencrypted card data.  The retailers would then shift the entire burden to the card merchants.

Jeff Jones

 
Mathew
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Mathew,
User Rank: Apprentice
3/27/2014 | 7:12:18 AM
Should PCI auditors be prohibited from selling security services?
Interesting follow-on from the news of the lawsuit from Gartner analyst Avivah Litan, who says that while she thinks the PCI standard is good, the PCI enforcement process needs fixing.

Furthermore, she argues, assessors shouldn't be allowed to also sell security services to their clients: "Gartner has long argued that PCI qualified security assessors like Trustwave should not be allowed to sell remediation and ongoing security services as Trustwave did for Target, according to the lawsuit. This has the effect of potentially destroying the integrity and independence of the assessment process," she says in a blog post.
kjhiggins
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kjhiggins,
User Rank: Strategist
3/27/2014 | 7:42:07 AM
Re: Compliance Does Not Mean Hack-Proof
Fallout from the Target breach already is speeding up the adoption of chip & pin (via Target), so maybe this legal case will spur debate and possible change with some of these PCI enforcement holes noted by Gartner's Litan.
Mathew
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Mathew,
User Rank: Apprentice
3/27/2014 | 7:51:24 AM
Re: Compliance Does Not Mean Hack-Proof
That's a fantastic idea. Hold card brands accountable for the security of the payment card infrastructure, as well as all related processing. And imagine if Visa had to prove that its payment processing black boxes and back-end infrastructure were PCI-compliant? That would be a poetic turn of events.
macker490
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macker490,
User Rank: Ninja
3/27/2014 | 9:36:47 AM
two rules of security
there are two rules to computer security:

1. the host o/s must not allow itself to be modified by the actions of a running application program.

2. the customer is responsible for the activities of the application programs running on its systems

 

i.e. oem is responsible for building secure operating software. customer is responsible for using software properly.   same as we do for cars and many other products for which we have established product liability.

it's time for product liability in software.

don't laugh at rule 1: the means for doing that have been built into x86 since 80386 when protected mode was added to the x86.
Drew Conry-Murray
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Drew Conry-Murray,
User Rank: Ninja
3/27/2014 | 10:29:46 AM
Re: Compliance Does Not Mean Hack-Proof
If the card brands really belive in PCI, I'd love to see them put some money on the line with an offer like this: if you are certified PCI-compliant and then get breached, the card brands will assume a share of the liability.

There's nothing fundamentally wrong with the PCI standards. The problem is that since PCI first came out, the PCI organization and the card brands have insisted that no compliant organization has ever been breached--in essence, saying that PCI compliance is equivalent to being breach-proof. Clearly that's nonsense: compliance does not equal perfect security, and it's a mistake to conflate those ideas.

The card brands get to set the rules for retailers via PCI, but there are no penalties for the card brands if those rules fail. It's the perfect catch-22: if you are certified compliant, and then subsequently breached, you must not have been truly compliant, because compliant companies don't get breached. Crazy.
Zimdog
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Zimdog,
User Rank: Apprentice
3/27/2014 | 12:09:21 PM
Re: Should PCI auditors be prohibited from selling security services?
It's rediculous to allow an assessor to provide remediation or other services to a client they've assessed.  It's a complete conflict of interest.
Ed Moyle
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Ed Moyle,
User Rank: Apprentice
3/27/2014 | 4:45:11 PM
Compliant vs. non-compliant is how hard you look
Back in the day when I was a QSA, I would tell folks that the difference between a compliant environment and a non-compliant one was in how hard you look.  

What I mean by that is that any large cardholder data environment is going to have some areas of non-compliance somewhere.  For example, consider a retail chain with 4000 locations.  Assuming that every location is going to be compliant with 100% of the standard is a recipe for problems.  To assess where the problems are, it's not workable economically (for either the retailer or the assessor) to do an assessment of every retail location, so you have to pick and choose what's in scope of the assessment vs. what isn't.  You're always picking and choosing: what machines you look at, what accounts you review, what stores you visit, etc.    

Two factors influence how realistic the assessment is: (1) how skilled the assessor is and (2) how much the retailer lies to you about what's really going on (because this happens more than you'd think).  For a #1 problem, holding the assessor's feet to the fire makes sense to me, but for #2 it seems like the assessor's not really the issue.  
Mathew
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Mathew,
User Rank: Apprentice
3/27/2014 | 6:36:43 PM
PCI Security Council Weighs In
I just heard back from Bob Russo, general manager of the PCI Security Standards Council, about the organization's POV on the lawsuit filed against Trustwave and Target. Here's what he says: 

As the Council does not conduct PCI compliance assessments, we cannot speculate on any specific assessment or any related lawsuits or ongoing investigations. The Council reminds organizations that a compliance assessment is just a snapshot in time and that passing a PCI compliance assessment at one point in time does not guarantee the ongoing security of your business or data. PCI Standards are a strong security baseline to help businesses prevent, defend and detect attacks on their systems with a layered approach. But just like a lock is no good if you forget to lock it, these controls are only effective if they are implemented properly and as a part of an everyday, ongoing business process.

marter25
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marter25,
User Rank: Apprentice
3/28/2014 | 2:13:44 PM
Re: Compliant vs. non-compliant is how hard you look
However, this is not Trustwave's first rodeo. A few years back a payment processor got breached and Trustwave was their QSA as well.
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