One big question is whether virtual environments will pass PCI audits. "One of the biggest challenges is that the virtualization vendors have no common taxonomy" for the PCI Council to prescribe the minimum best practices for securing data in virtualized environments, said Michael Legary, executive consultant and founder of Seccuris, a panelist on the Computer Security Institute's Security Exchange summit on virtualization.
And without those best practices, organizations that deploy virtual servers running their PCI data run the risk of failing an audit. Joshua Corman, principal security strategist for IBM ISS, said the best strategy for now is to avoid virtualizing any regulated applications. "Don't do it with highly regulated apps. For the next six months, do hard-core, deep immersion of a low-risk project," Corman said.
PCI DSS 2.2.1 prescribes that you "implement one primary function per server," Corman pointed out, and it all depends on how that is interpreted by an auditor. "A loose interpretation of this says you can virtualize [any PCI-related applications] at all," he said.
Issues such as whether virtualization's ability to dynamically relocate applications when one physical server gets too busy and another has extra capacity also muddies the PCI water. "With dynamic relocation, [apps and databases] might end up comingled," even though they weren't deployed that way to begin with, potentially violating PCI, Corman said.
Corman and other experts here said they expect the PCI standards body to clarify these gray areas eventually, but until then, it's better to be safe than sorry.
"Right now, virtualization is ahead of compliance," he said. "PCI is highly subjective and not specific now...Engage the auditors early...ask [them] how they are going to interpret it" prior to the actual audit, he said.
And while virtualization raises plenty of security risks of its own, it can also serve as a tool for incident response in the wake of an attack: Steve Orrin, director of security solutions at Intel, said here this week that features such as VMware's Record/Replay and Capture can be used in forensics.
You can take a "snapshot" of certain activity and look at it later, rather than shutting down the physical server in the event of a potential breach. It lets you capture potential evidence. "For some apps, you can set it up to copy, record, and play a transaction system," Orrin said. "And if you have that, IT can get back to it without stepping on any evidence."
Virtual machines also let you sandbox suspicious activity, he said. "The bad guys are already using virtual machines for malware analysis," Orrin said. "And in large IT organizations, virtualization could be a tool for analysis...of potential malware."
But using virtualization for forensics isn't easy, he warned. "It's not simple to implement. It requires some infrastructure," he said. "But it can benefit incident response and forensics. People are starting to think about VM capture as evidence."
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