Tag: Policies and Procedures

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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I am constantly surprised and disappointed that the Policy Set (policies, standards, procedures, and guidelines) aren’t taken more seriously. They are the blueprint of your corporate culture, the single most important aspect of your security program, and by far the easiest and cheapest things to put together (in terms of capital costs anyway).

Even a ‘controls only’ standard like the PCI DSS is roughly 40% ‘paperwork’, but, with the possible exception of the risk assessment, remains the most common tick-in-the-box exercise of them all. Which is a shame really, as it should be enough that thieves want to steal your data, to make things worse by not preventing your own employees from virtually giving it away is just plain dumb?

A Policy Set generally consist of 4 main components:

  1. Policies – the dos-and-don’ts of your entire organisation and use language like will / must / shall. e.g. Your authentication policy states that you; ‘MUST use strong authentication for access to systems containing data above a certain classification.’;
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  2. Standards – A very detailed document that explains exactly HOW something is to be configured. From operating system hardening guides to firewall rulesets. e.g. the details the actual password elements that constitute ‘strong’ (7 characters, alpha-numeric, change every 90 days etc.).;
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  3. Procedures – describe HOW you implement the policies in YOUR organisation. They are detailed, ‘living’ documents that prevent the constant re-inventing of the wheel when faced with performing standard functions. e.g. this is how you long into X system using 2-factor authentication.; and
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  4. Guidelines – The only non-mandatory element of the Policy Set, they provide good-practice guidance on how to implement a policy or standard requirement. e.g. For passwords, don’t use birthdays, don’t use names of children, consider a pass-phrase instead etc.

However, you can have the most polished documentation ever, and still completely miss the mark. It’s not about the paperwork itself, it’s about the enforcement of what’s IN the paperwork. A policy is only ever as good as the understanding of it, and the adherence to it.

Unfortunately, this is where most organisation fall down, and one or most of the following challenges apply:

  1. Policies not in-line with corporate culture or day-to-day business process – Policies should be owned, and even written BY the CEO / BoD. Who else is responsible for the culture, direction, and future of an organisation more than them? Too often this is delegated to departments or individuals without the necessary authority or experience to perform the function properly. A document coordinator MUST be a subject matter expert;
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  2. Undocumented procedures result in numerous (usually unintentional) breaches in policy outside of formal exception/variance processes – Just because a policy is in place, does not mean everyone knows how to implement it. Every department in an organisation is responsible to describe how each and every task is accomplished. Without procedures and standards, policies can become unenforceable, and every new employee has to reinvent the wheel every time they want to accomplish what should be a standard task;
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  3. Policies are undistributed, unenforced, or mis-understood – Just because you HAVE policies, or even procedures, if no-one knows where they are, what they mean, or how to measure against them, they are just pieces of paper. Security Awareness Training programs should start with a comprehensive look at ‘role-relevant’ corporate policies;
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  4. Poor document management or lack of integration with formalised training mechanisms – Without a robust document management system, it’s very difficult to both maintain the integrity of the Policy Set, and very difficult to distribute and enforce it; and/or
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  5. No feedback or measurement processes – Per the old misquoted cliché; ‘you can’t manage what you can’t measure‘, unless policies are seen as living documents with company wide feedback mechanisms in place, they can rapidly become obsolete.

I do not use the word ‘recommend’ lightly, but I HIGHLY recommend that before you implement ANY aspect of your security or compliance program, you get your Policy Set in place. At the VERY least do this in parallel with a risk assessment and business process mapping exercise.

While most high profile breaches focus on what went wrong technically, I can almost guarantee the original failure was one of education in the most basic of all security foundations; policies, standards, and procedures.

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To this day, people are surprised when an organisation is breached after having achieved PCI compliance.

Why?

The SSC has never claimed that PCI compliance ensured the protection of cardholder data, especially when you consider most organisations don’t DO PCI compliance for security, they do it to get their acquiring banks off their backs. All the SSC have ever claimed is that it helps, and it does.

Security is not about being impenetrable, that’s impossible, it’s about knowing your two main enemies; thieves and ignorance.

Thieves are lazy. In fact, I’d go as far as to say that laziness, more than a desire to be bad, is the leading driver behind computer crime. This drives them to steal first what is most easily available; the so called low hanging fruit. So to avoid thieves, just have YOUR fruit higher up the tree. That’s what PCI compliance does, and that’s all.

Continue reading “Stop Confusing PCI Compliance With Actual Security” →