Tag: PCI

While on the one hand, few organisations take information security as seriously as they should, to blame merchants for not maintaining PCI compliance is akin to blaming the doctor for your illness. In non-cash payments the fault lies not with the merchant’s lack of security culture, but with the payment card ecosystem itself.

I understand the motivation behind this article; Maintaining PCI Compliance a Showstopper for Many Retailers, but it shows a spectacular lack of understanding of the real issues.

The branded-card payment technology is broken, pure and simple, and so far no-one in the card-payments arena has done much to fix it. Instead, they have all put the onus, and the cost, onto the end merchant, who then has two choices;

  1. Eat the cost
  2. Pass the cost on to their customer

Guess which happens 9 times out of 10?

But why should the merchant be wholly responsible for the protection of the cardholder data? Are credit cards core to their business? They shouldn’t, and no, are the respective answers; payment for services / goods rendered is core, the means by which they receive payment is ancillary, and in this case then, responsibility for securing the payment type should be on the payment service provider.

50 odd years ago certain card brands came up with an excellent concept; the payment card. Banks jumped all over it and started providing lines of credit through the medium of plastic and the concept exploded. Now credit cards are the de facto, and ubiquitous, form of non-cash payment accepted globally.

So ubiquitous in fact, that few people seem to question the fact that the system is inherently insecure, inefficient, inflexible and massively expensive to maintain. Not for the card brands mind you, but for everyone else. The only ones who cannot recoup their costs is the consumer.

I have no problem paying for the convenience of a non-cash payment mechanism, but as a business owner, I DO object to being the only one paying for security of cardholder data when the technology itself is broken and any innovation away from the current system is stifled until such times as the card brands can catch-up. Which they won’t at the rate they are going.

The card brands clearly want things to continue as they are, as do the issuers and acquirers for obvious reasons. Banks make money from branded cards by charging both annual fees and interest on lines of credit so they have no desire to change things. Large retail, who should have enormous power and influence over payments innovation have, for some reason, completely missed the point. So it’s left to the rest of us to make a difference.

The challenge is that ‘we’ are ignorant and are clearly quite happy to go along with whatever is given to us. If this seems harsh, just look at the above article again. Verizon SHOULD know better than to blame the merchants, but if they don’t, what chance to the rest of us have?

Until such times are the ‘merchants’ learn ask the right questions this type of nonsense will continue, and until we, the ‘consumer’, start demanding REAL alternatives, we have no-one but ourselves to blame.

[Ed: I am very pleased to present a guest blog for a good friend of mine. He and I have spent more time in the PCI trenches than we would either care to admit;]

“I read your blog somewhat religiously and I find myself thinking about my feelings towards PCI both from an assessor and client perspective and moreover as a security professional.

With breaches now on the rise, it is time to reflect a bit on how did we get here? Why are things this way? Is PCI working?

We got here because of money. The all mighty dollar (pick your currency). Greed, my friends, has fueled this issue, and for years and will continue to do so.

Greed by the card brands has pushed them to promote acceptance so wide that the only way anyone even thinks about non-ash payments is with a card. This push for acceptance came in the early 1990’s and continues today. At that time, very little was thought of PCI other than a little fine print that was quietly overlooked until breaches began to result from this push.

At that point, the card brands felt that the public – being sufficiently hooked on the drug of convenience – was finally ready for enforcement of compliance with standards. Shortly thereafter the PCI SSC was born, and the real greed and corruption was to begin.

Below are a few points that have been smoldering quietly in the back of my head that are now demanding to be shared.

  1. Unless it’s my core business, it will never be my core competency. You cannot make merchants into military. They won’t go, they never will, stop trying to make them. Realize this now and move on.
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  2. The card brands have created the problem by pushing their acceptance channels as hard as they have, and then attempted to throw security on top of the pile long after the fact. Security first, acceptance of cards later.
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  3. The card brands added insult to injury by creating the PCI SSC. This is a self serving group that dictates a set of documents and charging fees, then completely and utterly fails to enforce its own assessor quality assurance program.
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  4. The SSC has, through their actions and inaction, contributed to the creation of a scandalously corrupt cottage industry of PCI QSACs. These companies are selling assessor services for a flat fee and assigning work at a rate of 35 to 45 PCI assessments a year per QSA. This volume is horrific and does not serve the client, or the card brands. The delivery of an appropriate assessment is simply not possible. You can have two of the three, “cheep”, “fast” and “good” but only two. Cheep and fast does not make for good, yet the SSC has allowed the QSAC’s to promote and aggressively sell just that.
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  5. The SSC has allowed the same QSAC and QSA to assess the same environments year after year creating complacency and further corruption. If you care about compliance, rotate assessors. Assessors make bad calls, and in order to maintain the client, must live with them year after year. Fresh eyes are critical to maintaining integrity.
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  6. The card brands have failed to adopt more secure methods of moving funds. The clear text account number adhered to the back of a piece of plastic via technology rivals that of the 8 Track player in my mother’s 1976 Mercury Cougar. This is criminal.

I could go on and on, but the key points remains the same, the card brands are the cause of the problem, and have made it worse by setting up an unrealistic security program rather than focus on their own flawed methods.

The reality is this; PCI is a way to shift the burden of securing the otherwise insecure from the card brands to the merchants, banks and service providers. God forbid the card brands pick up the tab??

As long as I am ranting, how is it that Moore’s Law drives down the cost of all technology except when it comes to transaction processing?

Will my rant change anything? No, but I do feel a bit better sharing with you all.

Regards,

Frustrated Assessor”

…or better still, keep doing what you’ve learned, all day every day.

This is the final post in my ‘Going Beyond the Standard’ series – HURRAH!! – and hopefully despite all of the spelling mistakes, grammatical errors, left-field rants, and miscellaneous off-topic diatribes that you have derived some benefit from it.

Timing is pretty good as well, seeing as the SSC came out with their Information Supplement: Best Practices for Maintaining PCI DSS Compliance, and I will say that I have to agree with the majority of its content. However, reading a book on emergency appendectomies does not make me a doctor, so when it comes to the implementation of the ‘staying compliant’ concepts, have an expert help you.

It takes someone very skilled to make things simple, do not half-arse your security.

There is nothing in PCI that you should not already be doing around all of your sensitive data, and there are no validation requirements that should fall outside of standard practices. In fact, you should be validating EVERY day, not once a year, and the only way to do that is to baseline everything and report against exceptions.

I previously used this ridiculous analogy; If every PCI requirement was a tennis ball, you could very easily carry them all from a weight perspective, but it’s impossible to hold them all together without some kind of container (Tennis ball = DSS Requirements, Container = Security Program). In other words, the requirements themselves are basic, but completely out of context from an ongoing management, business, or even good security practice perspective.

The reason PCI becomes so difficult to maintain is because security in general is too often seen as an IT project and not what it is; a business process. The only time it gets the attention it deserves is when there’s a problem, which is already too late.

When I started my own business, and when I began this blog, it was with the following premise; “Security Is Not Easy, But It Can Be Simple.” Yet every business for whom I have ever provided guidance were basically making a pig’s ear of it, and it always revolves around a lack in at least one, but usually all of the The 4 Foundations of Security.

The way I have always phrased it is; “If my boss does not care about something, guess how much I care about it?”, which is why I have made this statement several times now;

“Let’s be very clear; The CEO sets the tone for the entire company: its vision, its values, its direction, and its priorities. If the organisation fails to achieve [enter any goal here], it’s the CEOs fault, and no-one else’s.”

So if you get nothing out of this series of 25 blogs, take that away and do what you can to help them change the culture to one of accountability and responsibility across the entire organisation. It will pay dividends.

Hope you enjoyed the series, and I would welcome any guest blogs that either expand on the concepts on the subjects on which I am weakest (encryption, coding, charm, spelling etc.) or are better than mine if it’s a subject in which you are an expert.

There is no room for ego in security, everyone has to win.

You may be wondering why I would put this after Governance seeing as that seems to bring everything together, and you may also be wondering why I did not included Disaster Recovery (DR) in the same post as Incident Response (IR) which everyone else always does.

They would be good questions, and my reasoning is relatively simple; You cannot HAVE Business Continuity Management (BCM) without Governance so that must be formalised first, DR represents the detailed processes summarised in the BCM, and IR is the feed INTO the DR/BCM, not the output from it.

To put it another way; the Business Continuity Plan (BCP) details what must be done, in what order, and how quickly to save the business, DR puts that plan into effect, and IR would have uncovered the inciting incident that brought both the BCP and DR plans into play in the first place.

Assuming that made any sense, the question is; What if I don’t HAVE a BCP?

I am surprised every time I ask a client for a BCP and don’t get one. Mostly because I’m not too bright, but partly because it makes absolutely no sense to me that ANY organisation in any industry sector, anywhere in the world would not make such a simple effort to help themselves STAY in business. While both DR and BCP represent what amounts to contingency planning and will hopefully never have to be invoked (assuming your IR is top notch of course), NOT having a plan is nothing short of irresponsible.

There are several well known standards related to Business Continuity, and for obvious reasons they encompass more than just IT systems:

  1. ISO 22301:2012: Societal security — Business continuity management systems – Requirements
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  2. ISO 22313:2012: Societal security — Business continuity management systems – Guidance
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  3. ISO/IEC 27031:2011: Information security – Security techniques — Guidelines for information and communication technology [ICT] readiness for business continuity
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  4. NIST Special Publication 800-34 Rev. 1, Contingency Planning Guide for Federal Information Systems
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  5. ANSI/ASIS SPC.1-2009 Organizational Resilience: Security, Preparedness, and Continuity Management Systems

Unfortunately the ISO stuff will set you back a few hundred quid, so start with the NIST / ANSI stuff to ge yourself familiar enough with the concept to at least ask the right questions.

For DR, start with mapping out all of your business processes and asset dependencies. If you don’t know how things fit together, you’ll have no idea how to put them back in place. Clearly, if your asset management processes are not robust, you can’t even begin the mapping process, so get that done first.

Once you have mapped out your business processes, it’s a relatively simple task to organise all of your procedural documentation into how you reestablish all the moving parts. You have all that, right? So whether you have full redundancy in all things, hot swap, warm spares or a whole host of other DR clichés, how you get your systems back online boils down to a series of easily followed instructions.

From an IT perspective, all the BCP plan does is tell you in which order to bring those systems back online and in what timeframe. It should be needless to say – but it isn’t – the plan and all of its moving parts must be tested on an annual basis or even explicit instructions cannot get the response times to an optimal state.

No aspect of security should be performed half-arsed, DR and BCP processes are no exception. Even within the field of security BCP is a speciality, and making the plan simple and appropriate is a talent more than a skill. Expect to pay a lot for these services but rest assured it is money well spent.

Over the course of the last year the word ‘Governance’ appears in no fewer than 26 of my 130-odd posts, and if you have read any of those posts you know how many times it appears in the PCI DSS v3.0.

Not once

Going beyond the standard therefore is clearly very simple. HAVE governance and you’re way ahead of the game.

It does however get mentioned in the ‘Information Supplement: Best Practices for Maintaining PCI DSS Compliance‘ released August 2014, when they refer to an “overarching security framework”. You’ve all read that right?

They of course mention the usual suspects; CoBIT, ITIL, ISO 2700 series, and NIST, but quite rightly leave the choice and detail up to you, as well as make the most sensible statement I’ve seen yet coming out from the SSC officially;

“Integrating PCI DSS controls into a larger, common set of security controls is often the easiest path to ongoing PCI DSS compliance. Overarching security frameworks allow security teams to focus on a single target rather than trying to accommodate multiple (and sometimes conflicting) sets of requirements. It also provides for a common set of terms and metrics that can help avoid confusion when articulating security and compliance strategies to key stakeholders. When PCI DSS is integrated into an organization’s overall risk-based security strategy, it makes it easier to incorporate specific PCI DSS activities into the normal day-to-day operations of the security team. This, in turn, helps to ensure these activities are conducted on a regular, ongoing basis, which can make maintaining PCI DSS compliance a much more manageable task.“

But who manages this? There are no governance frameworks that will work without a governance FUNCTION.

The IT Governance Institute’s definition is: “… leadership, organizational structures and processes to ensure that the organisation’s IT sustains and extends the organisation’s strategies and objectives.”

Or to put it my way: “The business side and the IT side having appropriate conversations.” Sounds trite, but this is exactly what is missing in most organisations where the business side dictates the immediate goals while the IT side is left working tactically without any concept of where their actions fit into the whole; i.e. the business’s goals.

But it’s not always the business side’s fault, the IT departments in a lot of organisations start with saying no and work their way up from there. This gives them the reputation of being business-blockers and everyone in their right mind will work around those if they want anything done.

Regardless of fault – there is no room for the blame-game in security – this is easily resolved if both sides place nice and set up some form of governance function. Call it what you will, but it is responsible for the following;

  1. Business Continuity Management / Plan – As representatives of [almost] all departments, the governance function will be responsible for the development and maintenance of the business continuity processes, which will be owned and ratified by the CEO / BoD.
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  2. Risk Assessment / Business Impact Analysis – it is up to the governance function to ensure that the frequency, scope, and analysis of the RA / BIA processes are in-line with the business goals as handed down by the CEO / BoD
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  3. Vulnerability Management / Risk Register – Unless the function of analysing risk and putting some form of prioritised remediation plan in place is centralised, you can never implement appropriate security.
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  4. Change Control – Number 4 on my list, but EXTREMELY important! As I’ve said many times; If nothing in your environment changes, the only way risk can increase is by a change to the external threat landscape. Your vulnerability management process should take care of the external stuff, which, by strange coincidence, is also managed by governance.
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  5. Vendor Due Diligence / Technology Purchases – Tack-on requirement, but my OCD doesn’t allow for only 4 bullets. That said, both of these item have critical security implications and should have governance oversight.

The composition of the governance function, their charter, and their ongoing processes cannot be dictated by any framework or standard, and must be entirely suited to the organisation in question. Industry sector, political / geographical region, culture and so on all have influence on the final result, so this is not something I can address in a blog.

As usual, I will end this with an ‘if you don’t have the skill-set in-house, go find it’ comment, but when it comes to the development and maintenance of a good security program, nothing has more overarching influence and benefit than governance done well.

‘Simple and appropriate’ is the mantra here, like it is in all things related to information security.