IMPLEMENTING PCI IN THE CLOUD

CLOUD SECURITY VISIONARY

BOTH SIDES NOW

"Rows and flows of angel hairAnd ice cream castles in the airAnd feather canyons everywhereI've looked at clouds that way”

Joni Mitchell

SIDE 1 - CONSUMER

"But now they only block the sunThey rain and snow on everyoneSo many things I would have doneClouds got in my way"

Joni Mitchell

SIDE 2 – SERVICE PROVIDERS

CLOUD ANATOMY

CLOUD BENEFIT$

WHAT’S DIFFERENT

Security ~ THEM

Security ~ YOU

IaaSInfrastructure as a

Service

PaaSPlatform as a Service

SaaSSoftware as a Service

Security Ownership

WHAT’S DIFFERENT

Access Control

WHAT’S DIFFERENT

Vulnerability

MOST SIGNIFICANT

“Cloud” Provider Datacenter in London, U.K.

“Cloud” Provider Datacenter in Sao Paolo, Brazil

“Cloud” Provider Datacenter in Geneva, Switzerland

“Cloud” Provider Datacenter in Tokyo, Japan

“Cloud” Provider Datacenter in San Francisco, USA

Your Corporate D

ata?Accountability

CLOUDY ISSUES

Confidentiality AvailabilityIntegrityTrust: Lack of transparencyTrust: Identity management & access controlRisk managementLiabilityGovernanceCompliance

TOP THREATS TO CLOUD

Abuse & Nefarious Use:

Insecure Applications Programming:

Malicious Insiders:

Shared Technology Vulnerabilities:

Data Loss & Leakage:

Account, Service & Traffic Hijacking:

Unknown Risk Profile:

BASIC MISCONCEPTIONS

Cloud Benefits

Security Requirements

• "But its Cloud! How can you attack a Cloud?"• "There's security in anonymity".• "Time sharing" with a new name & technology.

CLOUD THINKING

Same as your existing server environment only virtualised and in someone else's Data Centre running on Windows and Linux with

Windows and Linux vulnerabilities

THE STANDARD

First published January 2005, the PCI DSS is a set of comprehensive requirements for securing payment data. V3 released last year.

A multifaceted standard that includes requirements for security management, policies, procedures, network architecture, software

design and other critical protective measures.

APPLICABLE

• All systems that connect to them

• All systems that process, store or transmit credit or debit cardholder data

6 GOALS, 12 REQUIREMENTS

264 CONTROLS

Implementing the PCI DSS in the Cloud is like...

THE QUESTION THEN

Salesforce - SaaS Q: How do you implement 264 detailed control requirements across a public cloud solution?

A: It depends .

Google AppEngine - PaaS

Amazon EC2 - IaaS

SCOPING IS EVERYTHING

COMPLIANCE KEYS

= Service Level Agreements

= Compensating Controls

SLA

7.2. Security. We strive to keep Your Content secure, but cannot guarantee that we will be successful at doing so, given the nature of the Internet. Accordingly, without limitation to Section 4.3 above and Section 11.5 below, you acknowledge that you bear sole responsibility for adequate security, protection and backup of Your Content and Applications. We strongly encourage you, where available and appropriate, to (a) use encryption technology to protect Your Content from unauthorized access, (b) routinely archive Your Content, and (c) keep your Applications or any software that you use or run with our Services current with the latest security patches or updates. We will have no liability to you for any unauthorized access or use, corruption, deletion, destruction or loss of any of Your Content or Applications. http://aws.amazon.com/agreement/#7 (2 February 2012)

Amazon Web Services™ Customer Agreement

REMEMBER

IaaSInfrastructure as a

Service

PaaSPlatform as a Service

SaaSSoftware as a Service

Security ~ THEMSecurity Ownership

Build it inContract it

in

SLA

7.2. Security. We strive to keep Your Content secure, but cannot guarantee that we will be successful at doing so, given the nature of the Internet. Accordingly, without limitation to Section 4.3 above and Section 11.5 below, you acknowledge that you bear sole responsibility for adequate security, protection and backup of Your Content and Applications. We strongly encourage you, where available and appropriate, to (a) use encryption technology to protect Your Content from unauthorized access, (b) routinely archive Your Content, and (c) keep your Applications or any software that you use or run with our Services current with the latest security patches or updates. We will have no liability to you for any unauthorized access or use, corruption, deletion, destruction or loss of any of Your Content or Applications. http://aws.amazon.com/agreement/#7 (2 February 2012)

Amazon Web Services™ Customer Agreement

Cloud Model

Physical Physical Plant Security, CCTV, Guards

Storage Host-based Firewalls, HIDS/HIPS, Integrity & File/log Management, Encryption, Masking

Network NIDS/NIPS, Firewalls, DPI, Anti-DDoS,QoS, DNSSEC, OAuth

Management

GRC, IAM, VA/VM, Patch Management,Configuration Management, Monitoring

Information DLP, CMF, Database Activity Monitoring, Encryption

ApplicationsSDLC, Binary Analysis, Scanners, WebApp Firewalls, Transactional Sec.

Trust Hardware & Software RoT & API’s

Governance Model

Find the Gaps!

Compliance Model

WHERE CANNOT BE MAPPED

• Conduct risk assessment

• Identify unacceptable risks

• Implement compensating controls! – Designed, accepted for the business– Must produce evidence– Accompanied by process

MODELLING

Governance and Enterprise Risk Management

Legal and Electronic Discovery

Compliance and Audit

Information Lifecycle Management

Portability and Interoperability

Security, Bus. Cont,, and Disaster Recovery

Data Center Operations

Incident Response, Notification, Remediation

Application Security

Encryption and Key Management

Identity and Access Management

Virtualization

Cloud ArchitectureO

pera

ting

in th

e C

loud

Governing the C

loud

QSA WORDS OF WISDOM

QSA CLIENT ADVICE

"Never trust the vendor"

QSA CLIENT ADVICE

• Don't believe what you hear. Get out of your office Go see it. Touch it. Taste it. Smell it. Its about due diligence.

• Interrogate vendors focusing on security, resiliency, recovery, confidentiality, privacy and segmentation. See if they twitch.

• PCI Compliance comes down to implementing the controls, compensating controls or just accepting the risk. Go through each control with your vendor (as applicable) and determine actions.

• If you don't see it in black and white in the vendor SLA, do not assume its there. If you do see it, go check it.

• Your mantra should be "How will you identify a breach?" At the end of the day, if you have a beach it will be your company's name in the paper, your company receiving the fine or your company in court - not the cloud provider.

• Do everything you can possible do. Then get your Acquirer's buy in.

• Get insurance.

QSA VENDOR ADVICE

"Never trust the client"

QSA VENDOR ADVICE

• Embrace it. Be proactive. Get out in front of it. Bring it up before they do.

• Know your subject matter. Clients need mentors.

• Be transparent. If you can't meet a compliance requirement, say it.

• Never twitch.

• Lay out liability in the SLA. Be clear. Be concise. State both what you are liable and what you are not liable for.

• Rephrase the question: "How will we identify a breach?"

• Get insurance

"I've looked at clouds from both sides now,from up and down, and still somehow,it's clouds illusions I recallI really don't know clouds...at all."

Joni Mitchell

A DIFFERENT PERSPECTIVE FROM:

www.riskfactory.com0800 978 8139

www.riskfactory.com0800 978 8139