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5 Ways To Think Outside The PCI Checkbox
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Marilyn Cohodas
Marilyn Cohodas,
 User Rank: Strategist
9/23/2014 | 10:13:32 AM
Re: Checkbox mentality > Roadmap v Best Practices
Thanks for the example, @gabehernandez9. I'd love to hear more from the Dark Reading community about their advice and tactics for navigating DSS.
gabehernandez9
gabehernandez9,
 User Rank: Apprentice
9/23/2014 | 9:19:34 AM
Re: Checkbox mentality > Roadmap v Best Practices
A roadmap need not be overly detailed with specific turn-by-turn steps.  It could be a composed of a series of sucessive milestones to help you on your way.  For example, a key tenant of PCI environments is the concept of "isolation".  Why not have a tactical and practical guide to explain typical steps to achive isolation at the network layer...something like this.

1. Create an inventory of all IP-enable devices that are part of a PCI environment

2. Create a separate environment (ideally physical with separate routers, switches, firewals etc, but must be logically separate) to host and enable the functionality of those PCI assets isolated from the coporate LAN

3. Apply the following hardening and access restrictions to the edge of the new PCI network in accordance with DSS section blahblahblah

4. Migrate the previously defined PCI assets to the new network.

4. Train network personnel how to access and support the new envionment with strong emphasis in maintainng isolation from coporate LAN systems and services.

 

And so on....

 

This is admittedly a very simplistic example but not far from what I've had to do multiple times with assorted teams to help them navigate the DSS.
Marilyn Cohodas
Marilyn Cohodas,
 User Rank: Strategist
9/22/2014 | 12:17:21 PM
Re: Checkbox mentality > Roadmap v Best Practices
Are we splitting hairs about the difference between a road map and a best practices? Yes, best practices may be overly generic to be particularly useful. But on the other hand, a roadmap view with turn by turn directions might be too specific to be of value to various industry segments, or companies of different sizes. 
Stratustician
Stratustician,
 User Rank: Moderator
9/22/2014 | 11:03:12 AM
Re: Checkbox mentality
I agree, in some ways, perhaps having a recommendations guide where organizations can benchmark against what other industry folks are doing would help.  In many cases, PCI seems overly daunting, especially for small and mid sized organizations, so having better guidance on "here's some examples of what companies are doing to check off those boxes" would help, or at least help prioritize the technologies/policies that would help reduce the overall threat gap and give folks a better idea where to start.
gabehernandez9
gabehernandez9,
 User Rank: Apprentice
9/22/2014 | 9:09:09 AM
Re: Checkbox mentality
Education is always valuable, but for my money the Council would increase it's value by providing a roadmap to help companies achieve compliance when starting from square one.  I've encountered a lot of frustration with the DSS, not because it sets some aggressive security standards, but because those standards don't provide enough guidance on getting there.  Admittedly, Standards are meant to only stipulate the "What" as far as Security controls objectives to meet, but we could all use a lot more help with the "How" of getting there.  Not necessarily with a list of products or tools, but a cohesive tactical roadmap template that any businees can use and modify (within reason) to get to the compliance finish line.
Marilyn Cohodas
Marilyn Cohodas,
 User Rank: Strategist
9/22/2014 | 8:16:09 AM
Checkbox mentality
It's hard to argue with any effort that will up the card industry's game when it comes to data security. But I don't think education alone will turn the tables. The problems run deeper than an attitude shift and a new set of of best practices. Thoughts anyone?

 


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