Category: Security Good Practices

The thing with security is that there is always more than 1 top priority, so the trick is not to choose which comes first, it’s to get them ALL assigned and moving forward at the same time. There are simply too many interdependencies, and you will only avoid the inevitable road-blocks or analysis paralysis if you plan accordingly.

Asset Management is one of those top priorities, and is at the core of everything else you will ever do in the development, maintenance, and continuous improvement of your security program.

If you do it properly that is.

Prior to v3.0 of the DSS, the requirement for asset management only went so far as an understanding of every system type, function, and number of them. Basically a spreadsheet to support the sample sizes and PCI validation efforts. But this undermines the entire assessment process itself, as the whole point of an assessment is that you are able to make educated judgment calls. Knowing that you have 20 Windows web servers tells you nothing about the potential impact of their loss, for example.

I think everyone’s heard the famous mis-quote by Peter Drucker; “If you can’t measure it, you can’t manage it.”, but how do you measure the value of an asset? The answer, like everything else in security, is simple. Not easy, and pretty much never done well, but it IS simple;

“The value of each of your assets is directly related to the value of the data that flows through it.” and;

“The value of your data is directly related to its importance to your business.“

If you don’t know the above values you have a lot more problems than security.

It does not matter whether or not the ‘value’ is in financial or criticality terms, what matters is that every other security process must directly reflect its relative importance to your organisation. Does a web server have more importance to an e-commerce only merchant than it does to a plague/nest/whoop of lawyers (or whatever their collective noun is)? Maybe, maybe not. Would you expend far more effort protecting your intellectual property than you would your public web content? Of course you would, unless you’re irretrievably stupid (my favourite quote from A Fish Called Wanda).

But what IS an asset? It’s not just your servers, network devices and software, it’s your locations, your vendors, your business processes, and just as importantly, it’s your PEOPLE. Or more to the point, your people’s knowledge and skill-sets. There are often many single-points of failure in most organisations, and the one that’s most often overlooked is the human factor.

Unless you include ALL of these things, none of the following business processes will be anywhere near as effective, and perhaps not even possible:

  1. Risk Assessment – No point trying to examine your risks if you don’t know what those risks are related to.
  2. Gap Analysis & Security Control Acquisition – A logical follow on from a risk assessment, what are the gaps you have to fill? Can you use existing assets?
  3. Change Control – How can you give appropriate attention to change requests if you have no indication of regulatory relevance, maximum data classification, or the business criticality?
  4. Automated / Continuous Compliance Validation – If [for example] you don’t have a list of all the running services and listening ports against your systems, how can you hope to automate the detection of policy / compliance violations?
  5. Business Transformation – Try adjusting your business in the face of competition when you don’t know what you have and how it fits together.

Quite simply, Asset Management is too important and too core to security to give it real justice in a blog. Suffice to say, it is one of the easiest ways to centralise the required information to support every other process used to manage your security program. It is because Asset Management is so overlooked by PCI that everything else is seen as being so difficult.

This is one of the few areas where I actually recommend you look into implementing technology. An Asset Management System (AMS), especially if it forms the core of a Governance, Risk and Compliance tool. Surprisingly few do.

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It is the job of every QSA to help their clients reduce their scope as much as humanly possible prior to inflicting the remainder of the assessment processes upon them. Even the very far from ideal Prioritised Approach from the SSC alludes to this in Milestone 1: Remove sensitive authentication data and limit data retention.

While the remainder of the Prioritized Approach can effectively be ignored, removing ANY sensitive data that is not required will automatically reduce risk. And once the redundant instances of data have been removed, hopefully the number of systems that transmit, process or store card holder data have been equally reduced.

The second part of the scoping exercise is to ensure that ONLY the systems in-scope for PCI are in-scope, and other systems which could be deemed in-scope-by-association are minimised.

There are 3 things that can put a system into scope for PCI:

  1. It directly transmits, processes or stores card holder data – obvious, and will include things like points of sale (POS), back-office servers, network devices and the like.
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  2. It’s in the same subnet / VLAN as a device that matches 1. above – not quite so obvious, and provides the greatest opportunity for scope reduction. e.g. you have 2 web servers in your DMZ but only one is relevant to e-commerce. By putting these servers in 2 completely separate VLANs, you can most likely take the non e-comm server out of scope entirely.
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  3. It has significant impact on a system that matches 1. or 2. above – This can include things like active directory / scanning servers / log servers / jump servers / system admin laptops and so on, and while they may never directly touch CHD, can significantly affect the security of ones that do. Being in-scope in this category does not necessarily put the other devices in the same subnet in scope, but you need to be careful here.

Unfortunately this is where most organisations start to make the biggest mistake in PCI; focusing on just the in-scope systems. Just because it’s no longer in scope, does NOT mean it should now be excluded from the processes necessary to bring the in-scope systems into compliance with what amounts to the barest minimum of security controls.

Not being in scope for PCI just means it’s a lower priority, and even then you can only make that determination if you have properly performed a Risk Assessment in conjunction with the company-wide data classification and asset management mechanisms. A good QSA will always ask for a risk assessment before they ask for a network diagram.

Segmentation to reduce scope should never, EVER, be exclusive to card holder data and PCI compliance, it should be part of an enterprise-wide project to ensure that all systems have the necessary level of protection per their data classification and their overall criticality ranking to the business.

Any effort to segment based on PCI should be appropriate, sustainable, and above all SIMPLE. Over the course of time organisations can grow organically with new business processes being tagged on to existing ones, and networks becoming more and more complex and ungainly. Unless these changes are implemented with simplicity in mind they can become rapidly unsustainable, and security itself goes out the window.

A good QSA will be able to determine scope and potentially some scope reduction options, a good CONSULTANT will be able to help you define your optimal network and segmentation infrastructure, so choose your help wisely.

Been composing this blog for several months now, and it started when I was thinking about how superstitions begin; It’s bad luck to walk under ladders, or it’s 7 years of bad luck if you break a mirror for example.  And then it occurred to me that these superstitions were probably the only way to scare children into, or out of, certain behaviour.

Walking under ladders, well duh, things fall OFF ladders, so don’t walk under them, and mirrors used to be really, REALLY, expensive, so telling children that breaking them would have horrific consequences makes a lot of sense (in a very negative way of course). I’m surprised that playing with matches didn’t become a superstition, but then again, household-use matches were not readily available until the 1800’s.

Unfortunately, these things have a way of sticking around long after the original cause is either meaningless, or worse, is twisted and perverted by those with a vested interest in the status quo. ‘Heretics’ were burned at the stake for suggesting that the Earth revolved around the Sun, and not the other way around*, and ‘witches’ were similarly killed in horrific ways when they suggested that herbal remedies were better than leaches and other forms of bleeding. Priests and Doctors respectively were very protective of their power.

Human nature has changed very little since then, only societal laws and the more progressive ‘norms’ keep the peace.

I have for years likened information security to insurance, in that no-one wants to spend money on it, but they know it’s a cost of doing business. And more recently I have likened security to the law, because it’s becoming so complex in terms of regulation / legislation / standards etc, that’s it’s often out of reach for the organisations and individuals who need it most.

Now I find myself likening security to superstition, because from the way we’re going, it won’t be long before being in security will have the same stigma as being a tax auditor, a parking enforcer, or a lawyer. QSAs are almost there already because the entire concept of PCI is so limited, but there is no reason true security professionals should not be seen in the same light as those responsible for driving revenue growth or competitive innovation.

Security departments are something people go out of their way to avoid, or to circumvent. They are seen as the department-who-says-no, who will stifle innovation and good ideas, and generally do the one thing that would label them heretics; get in the way of revenue.

Nothing could be further from the truth, as no other department has the knowledge and DESIRE to do the things that make staying is business possible:

  1. Innovation: It’s the 2000s, the vast majority of innovation now is in technology. Who else is best placed to pick the RIGHT technologies to ensure that innovation is implemented in a way that enhances the organisation and not just adds risk?
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  2. Business Transformation: Competitive advantage in the information age is now measure in weeks and months, not years, organisations without the ability to adjust critical business processes quickly and appropriately will be left behind. What other department has the knowledge of exiting processes to enable the adjustments?
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  3. Revenue Protection: Can you think of anything worse than seeing all your revenue disappear into the hands of regulators because your focus on selling failed to take into account that your processes for doing so were completely inappropriate. I understand completely the pressures, but revenue generation is not about doing what it takes, it’s about doing what’s right.
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  4. Reputation Protection: I could have put this under revenue protection, but wanted to break this out as corporate reputation goes way beyond just revenue, and my OCD will not allow for an even number of bullet points. Damage of reputation through loss of data C.I.A. can have long-term negative effects on a business, just ask CardSystems who went from $25M / annum to out of business in less than 1 year after their breach.
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  5. Infrastructure Investment Optimisation: OK, long title, but consider that the amount of money spent on PCI is already in the multi-billions, when a huge chunk of that could have been save by adjustments in PROCESS. Technology purchase is the last resort of a true security professional.

I really don’t have an answer to HOW we can ensure our reputations remain unsullied, and there are a lot of so called security experts out there giving the rest of us a bad name, but I think the worst thing to do is fall back one of the phrases I hate most in this world; “It is, what it is.”

Actions speak louder than words, and I will never stop trying to show my clients that security is something to be embraced, not avoided.

Forward this to all your friends or you’ll have 3 years of bad luck.

For first timers to PCI; Regardless of the security posture you THINK you have, the specific controls in the PCI have always – in my experience – resulted in several major efforts in a number of areas. These should be defined up-front and worked in parallel to minimise your efforts and bring your compliance date forward.

For re-certifiers; If you didn’t put management controls around the PCI validation requirements in previous years, you will be doing much of this all over again, at least in terms of providing validation evidence.

PCI compliance is impossible without remediating the relevant action items to do so, and these will not be done until such times as a named person is assigned the task. Not a role, not a department, a person, with a due date and transparent accountability up his/her management chain.

The first step is to define what those major project are in your organisation, then assign a Project Manager to each and every one. I’m not saying you need to hire additional staff, but unless there is a named person in charge of a SPECIFIC goal, things will simply not get done. The trick, however, is to ensure that these people are fully aware of their responsibilities and action items at the very beginning, or the nasty surprises – for which PCI is infamous – will cause roadblock after roadblock.

That’s really all PCI is, a series of action items assigned to an individual, and a QSA in the wings to provide all necessary guidance to keep things moving forward. The better QSA companies understand this, and will have a well defined and proven methodology to take ANY organisation where they need to go. If that’s PCI compliance only, so be it, but a real QSA will give you the option to take the exact same programme all the way to real business-enabling security.

Generally, these are the major projects required for PCI, along with the generic role names usually best placed to own them;

  • DSS Requirements 1.x: Review of firewall / router configuration standards and rule sets / ACLs.
    Role(s): Network Administrators
  • DSS Requirements 2.x: Configuration / Hardening standards for all system types, plus business justification for all functionality (i.e. Running services and listening ports)
    Role(s): System Administrators, Network Administrators, Application Developers, DBAs
  • DSS Requirements 3.x: Encryption of data at rest (hopefully not applicable)
    Role(s): Application Developers, DBAs
  • DSS Requirements 4.x: Encryption of data at in motion – SSL / HTTPS / email etc.
    Role(s): Application Developers, Web Developers
  • DSS Requirements 5.x: Anti virus
    Role(s): System Administrators
  • DSS Requirements 6.1.x – 6.2.x: Vulnerability management (including patching)
    Role(s): [All roles, managed centrally as overarching project]
  • DSS Requirements 6.3.x – 6.5.x: Secure coding / SDLC
    Role(s): Application Developers, Web Developers
  • DSS Requirements 6.4.x: Change control
    Role(s): [All roles, managed centrally as overarching project]
  • DSS Requirements 7.x: Access control
    Role(s): [All roles, managed centrally as overarching project]
  • DSS Requirements 8.x: User ID management / Password complexity
    Role(s): [All roles, managed centrally as overarching project]
  • DSS Requirements 9.1.x – 9.4.x: Physical security at data centres
    Role(s): Facilities / Data Centre Manager 
  • DSS Requirements 9.5.x – 9.10.x: Media management
    Role(s): System Administrators
  • DSS Requirements 10.1 – 10.3.x: Logging attributes
    Role(s): [All roles, managed centrally as overarching project]
  • DSS Requirements 10.4.x: Time synch processes
    Role(s): System Administrators, Network Administrators
  • DSS Requirements 10.5.x – 10.7.x: Log collection, protection, monitoring and retention
    Role(s): [All roles, managed centrally as overarching project]
  • DSS Requirements 11.1.x – 11.3.x: Wireless access point detection, internal/external vulnerability scanning and penetration testing
    Role(s): [Network Administrators, managed centrally as overarching project]
  • DSS Requirements 11.4.x: Intrusion Detection/Protection Systems
    Role(s): [Network Administrators, managed centrally as overarching project]
  • DSS Requirements 11.5.x: File Integrity Monitoring
    Role(s): [System Administrators, managed centrally as overarching project]
  • DSS Requirements 12.1 – 12.5.x: Policy attributes
    Role(s): [Management Designate, managed centrally as overarching project]
  • DSS Requirements 12.6.x: Security Awareness Training
    Role(s): [Management Designate, managed centrally as overarching project]
  • DSS Requirements 12.7.x: Background Investigations
    Role(s): [Management Designate, managed centrally as overarching project]
  • DSS Requirements 12.8.x: Vendor management and due diligence
    Role(s): [Management Designate, Procurement, managed centrally as overarching project]
  • DSS Requirements 12.9.x: Incident response
    Role(s): [All roles, managed centrally as overarching project]

As you can see, a lot of these projects will either be multi-PM’d (you’ll have a separate configuration standard for each system for example), or SHOULD be handled centrally (no point in doing logging in any way but centrally, and as a corollary, Incident Response). Unless some of these things are centralised and maintained centrally, sampling becomes very difficult.

In PCI sampling starts out at 100%, you must earn a reduction in that. The only way to do that is to show how you have: 1) installed all systems identically, maintained them identically, managed them centrally, monitor them centrally and show this from a centralised console of some sort. More on this in later ‘Beyond the Standard’ blogs.

There may be more or less projects in your environment, but unless you engage a QSA at the beginning of these exercises there is no guarantee your hard work will get you where you need to be. PCI is simple when you know what to do, so if you DON’T know, ask.

Of the roughly 400 separate requirements in the PCI DSS, 46% of them require the review or examination of some form of documentation. From policy, to procedure, to configuration standard to diagram, a very significant chunk of achieving PCI compliance starts with paperwork.

How is it then that in the 10 years I’ve been performing PCI and PCI-esque assessments the ‘paperwork’ is almost invariably the last thing to close? I’ve seen large organisations get centralised logging in place before they managed to get their policies and procedures in order.

In Want REAL Information Security? Start With Your Policies I have already gone into why organisations should take polices and procedures more seriously, so I’m not going to repeat myself. But I will just say now that if you didn’t start your project to formalise your policies and procedures at the beginning of your assessment, stop, go back, and start there. A good QSA will fail you for crap policies just as quickly as they would for lack of encryption on stored card holder data.

All too often the client response to a request for documentation is to provide a handful of polices taken from the internet with the company name changed, but no effort whatsoever to customise the content in line with reality. Procedures are virtually non-existent, everything is in unprotected Word docs, several years old, and in no way standardised. The look on the faces of those being asked to provide just the location of the official copies is usually one of confusion, or worse, blank incomprehension.

The worst thing you can do is hand your QSA a bunch of crappy docs and say “You tell me what’s missing.” It does not work that way, and all you’ve done is thoroughly irritate someone who should be on your side. It is YOUR job as the client to tell the QSA which documents and specific language YOU think meets the intent of the DSS requirement testing procedures. The best way to do this (if you don’t have access to a GRC tool with DMS built-in, see below) is just to start with the DSS on a spreadsheet and map your existing documents to it. Your QSA will tell you the gaps, which gives you the necessary action items to begin your remediation.

Here’s the one I give my clients, help yourself; PCI DSS v3.0 – Document Mapping Matrix

Other stuff:

  • Policy Content – In terms of policies, procedures and standards, these are the major headings I generally expect to see; PCI DSS v3.0 – Policy & Procedure Checklist.
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  • Document Management System (DMS) – This does not have to be a major expense, a folder on an intranet share will suffice, but the point is to have a centralised location to place all of your latest approved documents. They should however have access control mechanisms in place to ensure only those with a real need to see them, can. Some of the more elaborate DMSs will take care of version control, ownership, review cycles and so on, as well as automated mappings to regulatory compliance regimes like PCI. Choose what’s right for your business, and look at the Governance Risk & Compliance tools that may have this built-in.
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  • Pre-Packaged Templates – There are many organisations that can offer pre-packaged policy templates, but none that can provide pre-packaged procedures. Best practice policies are numerous and can be customised to suit your business, but procedures are written by your organisation and are necessarily specific to it. Don’t buy anything claiming policies AND procedures out of the box, and don’t buy anything specific to PCI. Cover your business, and if you have to spend money to get your ‘paperwork’ together, focus more on expert guidance. Avoid policies that match the next two points.
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  • Monolithic vs. Modular – It is generally best to have each of your separate policies as stand alone documents with their own version history and ownership, a single policy document is very hard to maintain.
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  • PCI Relevance – The phrase ‘card holder data’ should appear only once, maybe twice, in all of your policies; in the Data Classification Policy. Every other policy refers to the classification in which card holder data was contained (e.g. Highly Confidential).

Like everything in security, getting policies right is not easy, but it is simple. There are many people out there who can help you if you don’t know where to start, and this is not something you should do half-arsed.

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