PCI: THE ESSENTIALS

A simple, easy to use, online, B2B procurement portal for purchasing products and services to

identify, minimise and manage the security threat to business data.

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THE ESSENTIALS

• What PCI compliance is and why its important• Understand how to identify potential risks to card

data within your business• Foundation in data risk management • How to communicate the importance of PCI to

stakeholders• The keys to achieving and maintaining compliance• How to avoid fines

The Standard

WHERE DID IT COME FROM?

Restaurants sue POS vendor over data breach: Dec’09 Nearly 100 customers had their identities stolen as a result of "Aloha" POS software payments terminals that were not PCI-DSS compliant. They have to pay for forensic audits to trace the problems, reimburse fraud costs to the credit card companies and pay for re-issuance of credit cards to affected individuals.

Security Scans

Self-Assessment Questionnair

e

On Site Audits

Community Meeting

Industry Best Practic

es

Approved Scanning Vendors (ASVs) and Qualified Security Assessors (QSAs)

Proactive feedback

from QSAs,

ASVs and POs

PCI Data Security Standard

ADC Forensic

s Results

Advisory Board

THE STANDARD

6 Goals

12 Requirements

264 Controls

APPLIES TO:

Systems that store, process or transmit cardholder data

Systems that connect to them

Compliance is mandatory Enforced through merchant services agreements

6 GOALS, 12 REQUIREMENTSThe PCI DSS standard is based upon the following 6 core principles and 12 requirements: 264 controls

Build and Maintain a Secure NetworkRequirement 1: Install and maintain a firewall configuration to protect cardholder data.Requirement 2: Do not use vendor-supplied defaults for system passwords and other security parameters.

Protect Cardholder DataRequirement 3: Protect stored cardholder data.Requirement 4: Encrypt transmission of cardholder data across open, public networks.

Maintain a Vulnerability Management ProgramRequirement 5: Use and regularly update anti-virus software.Requirement 6: Develop and maintain secure systems and applications.

Implement Strong Access Control MeasuresRequirement 7: Restrict access to cardholder data by business need-to-know.Requirement 8: Assign a unique ID to each person with computer access.Requirement 9: Restrict physical access to cardholder data.

Regularly Monitor and Test NetworksRequirement 10: Track and monitor all access to network resources and cardholder data.Requirement 11: Regularly test security systems and processes.

Maintain an Information Security PolicyRequirement 12: Maintain a policy that addresses information security

264 CONTROLSRequirement 1: Install and maintain a firewall configuration to protect cardholder data.

1.1 Establish firewall configuration standards that include the following: 1.1.1 A formal process for approving and testing all external network connections and changes to the firewall

configuration. 1.1.2 A current network diagram with all connections to cardholder data, including any wireless networks. 1.1.3 Requirements for a firewall at each Internet connection and between any DMZ and the internal network zone

(intranet). 1.1.4 Description of groups, roles and responsibilities for logical management of network components. 1.1.5 Documented list of services/ports necessary for business. 1.1.6 Justification and documentation for any available protocols besides hypertext transfer protocol (HTTP) and

secure sockets layer (SSL), secure shell (SSH), and virtual private network (VPN). 1.1.7 Justification and documentation for any risky protocols allowed - for example, file transfer protocol (FTP), which

includes reason for use of protocol and security features implemented. 1.1.8 Quarterly review of firewall and router rule sets. 1.1.9 Establish configuration standards for routers.

THE STRUCTURE

6 Goals

12 Requirements

264 Controls

CARDHOLDER DATA?

Card (PAN) number

Magnetic stripe

Expiry date

Chip

Card account number

CONTROLS-2-DATA

SCOPING

DE-SCOPING

• Network segmentation is not a PCI DSS control requirement

• De-scoping is where you set the cost baseline for the project.

• Take your time.

• The more you can take out of scope – the less it will cost to implement the controls.

QUIZ 1

1. The PCI DSS applies to all systems that ________, __________, or _________ card data.

2. The PCI DSS is comprised of _________ principles, ___________ requirements and 264 controls.

3. The PCI DSS is a checklist of controls. True/False?4. Controls only apply to systems “in scope”.

True/False?5. We can store sensitive card holder data.

True/False?

The Players

THE PLAYERS

Card Brands PCI Council Acquirers QSA ASV Merchants Service Providers

RELATIONSHIPS MATRIX

Cardholder DataTargeted

CardholderVictimized

RegulatoryEnforcement

GovernmentIntervention

MediaScrutiny

CONCERNS & CONSQUENCES

Service Provider CardholderMerchant

Acquirer

CARDHOLDER DATA EXPOSURE

Payment Application

Service Provider

Service Provider

SERVICE PROVIDERS

Businesses that facilitate: process, storage or transmission of card data on behalf of Merchant or Acquirer.

Any business requiring connectivity to a card holder network or application.

QUIZ 2

1. The __________ issue fines for non-compliance.2. A service provider is defined as either

______________ or __________________.3. Merchant Levels are determined by the _________

of ___________ per __________.4. QSAs are monitored by _______________5. The Acquirers set the compliance deadlines for the

Merchants. True/False?

ComplianceProcess

PROCESS

Gap Analy

sis

Remediatio

n

QSA Validation

Report of

Compliance

Attestation

of Compliance

Acquirer

Card Brand

s

KEY DOCUMENTATION

Card Data Security Policy Comprehensive Network Diagram Evidence 3rd Party Agreements End User Agreements Security Vulnerability Scan Reports Security Penetration Reports

KEY ACTIONS

Gap Analysis Remediation Monthly Acquirer Reports Audit-ready (Evidence in place) Pass ASV scan Network Security Penetration Test Application Security Penetration Test Validation RoC to Acquirer / Card Brands Annual Revalidation

PROCESS – NOT A CHECKLIST

Identify

Minimise

Manage

QUIZ 3

1. RoC is an acronym for ____________ on ____________.2. AoC is an acronym for ____________ of ____________.3. SaQ is an acronym fro _________ ________ ________.4. I need to pass both an ASV scan and penetration test

prior to validation. True/False. 5. These quizzes are getting on my nerves. True/False

Exercise

Situation: You have a bank owned terminal (BOT) taking credit card payments at your site. It is connected directly to the bank and is not connected to your local systems.

Problem: Is it “in scope” of PCI DSS? Design a process for determining your answer.

Dilemma: What problem do you still have?

The Policies

FRAMEWORK

Annex C• Hosting

Provider Security

Annex B• 3rd Party

Connectivity

Annex A• Appropr

iate Use

Corporate Policy

POLICIES

1. INTRODUCTION• Required for the protection of client card data.

2. APPLICABILITY• All employees, contractors and 3rd party suppliers.

3. COMPLIANCE• Compliance Manager monitors & enforces• Collaborative effort• Non-compliance = disciplinary action

4. REVIEW, UPDATES & MAINTENANCE• Annual• 30 days after significant changes

5. EXCEPTIONS• Require Compliance Manager’s prior approval

6. PROGRAM MANAGEMENT

POLICIES

6.1 ANNUAL DOCUMENTATION Current network diagram Card data asset register Card data flow diagram clearly indicating all credit card dependant business processes List of all roles having access to card data 3rd Party Statements of Compliance

6.2 INFORMATION SECURITY RISK ASSESSMENTS Annually Prior to significant changes

6.3 MINIMISE HOLDINGS6.4 CARD DATA ASSET REGISTER Maintain current list of all devices hosting card data

6.5 ASSET CLASSIFICATION Hardware & software marked “Company Confidential”

POLICIES

6.6 EMPLOYEE CHECKS• Staff with access to card data = criminal & credit checks

6.7 SECURITY TRAINING• Initial• Annual update

6.8 3rd PARTY CONNECTIVITY AGREEMENTS• Condition of connectivity

6.9 3rd PARTY COMPLIANCE6.10 3rd PARTY AUDITS

• Initial• Annual verification

POLICIES

6.11 NETWORK SECURITY VULNERABILITY SCANNING Done quarterly – Pass – submitted to Acquirer

6.12 NETWORK SECURITY PENETRATION TESTING Annually After significant changes

6.13 APPLICATION SECURITY PENETRATION TESTING Applies to all application process/store/transmit Conducted prior to launch After significant changes Annually

7. SYSTEM SECURITY7.1 FIREWALL & ROUTER CONFIGURATIONS As stated in Annex

POLICIES

7.2 PASSWORDS & SECURITY ADMINISTRATION• Vendor accounts & defaults removed• Admin access encrypted • Configuration security build standards

7.3 CARD DATA STORAGE• Minimise!• Data Retention Policy• Do not store authentication data

7.4 CARD DATA TRANSMISSION• Encrypted when sent over public networks (email, etc.)

7.5 ANTI-VIRUS MANAGEMENT• Software on all systems that process, store or transmit card data

7.6 SYSTEM MONITORING• Quarterly testing for wireless - Implement IDS - File integrity monitoring

POLICIES8. APPLICATION SECURITY

• Software security development lifecycle procedures• Change control procedures as detailed in Annex • Patches• Process to keep up to date with new application threats

9. LOGS & RECORDS• System logs as detailed in Annex

10. SYSTEM USER SECURITY• Need to know• Password• Screensaver, lock outs

11. PHYSICAL ACCESS CONTROLS• Facility access control, locks alarms• Visitor badging• Protection of hard copy card data

QUIZ 4

1. The Card Data Security Policy only applies to your employees. True/False?

2. __________ is responsible for 3rd party compliance verification.

3. Credit and criminal records checks need to be conducted for all employees. True/False?

4. Identification badges are required for access to any facility. True/False?

5. This guy uses way too much mousse in his hair. True/False.

The Controls

CONTROLS

Requirement 1: Install and maintain firewall configuration to protect cardholder data.

1.1 Establish firewall configuration standards that include the following: 1.1.1 A formal process for approving and testing all external network connections and changes to the firewall

configuration. 1.1.2 A current network diagram with all connections to cardholder data, including any wireless networks. 1.1.3 Requirements for a firewall at each Internet connection and between any DMZ and the internal network

zone (intranet). 1.1.4 Description of groups, roles and responsibilities for logical management of network components. 1.1.5 Documented list of services/ports necessary for business. 1.1.6 Justification and documentation for any available protocols besides hypertext transfer protocol (HTTP)

and secure sockets layer (SSL), secure shell (SSH), and virtual private network (VPN). 1.1.7 Justification and documentation for any risky protocols allowed - for example, file transfer protocol

(FTP), which includes reason for use of protocol and security features implemented. 1.1.8 Quarterly review of firewall and router rule sets. 1.1.9 Establish configuration standards for routers.

EVIDENCE

Types• Observation (configuration or process)

• Documentation

• Interview

• Technical (monitoring of network traffic)

Required for each and every control !

CONTROLS EXAMPLE

Requirement 1: Install and maintain firewall configuration to protect cardholder data.

1.1 Establish firewall configuration standards that include the following:1.1.1 A formal process for approving and testing all external network connections and changes to the firewall configuration.

Observation (configuration) Observation (process) Documentation (firewall rule set) Interview (systems administrator) Technical (monitoring of network traffic)

COMPENSATING CONTROLS

Used only when a specific control cannot be implemented due to a business process Implement “risk-based” supplementary control(s) Designed for the business Accepted by the business Must be accompanied by supporting evidence Accompanied by supporting processes

COMPENSATING CONTROLS Information Required Explanation1. Constraints List constraints precluding compliance

with the original requirement.Company XYZ employs stand-alone Unix Servers without LDAP. As such, they each require a “root” login. It is not possible for Company XYZ to manage the “root” login nor is it feasible to log all “root” activity by each user.

1. Objective Define the objective of the original control; identify the objective met by the compensating control.

The objective of requiring unique logins is twofold. First, it is not considered acceptable from a security perspective to share login credentials. Secondly, having shared logins makes it impossible to state definitively that a person is responsible for a particular action.

1. Identified Risk Identify any additional risk posed by the lack of the original control.

Additional risk is introduced to the access control system by not ensuring all users have a unique ID and are able to be tracked.

1. Definition of Compensating Controls

Define the compensating controls and explain how they address the objectives of the original control and the increased risk, if any.

Company XYZ is going to require all users to log into the servers from their desktops using the SU command. SU allows a user to access the “root” account and perform actions under the “root” account but is able to be logged in the SU-log directory. In this way, each user’s actions can be tracked through the SU account.

1. Validation of Compensating Controls

Define how the compensating controls were validated and tested.

Company XYZ demonstrates to assessor that the SU command being executed and that those individuals utilizing the command are logged to identify that the individual is performing actions under root privileges

1. Maintenance Define process and controls in place to maintain compensating controls.

Company XYZ documents processes and procedures to ensure SU configurations are not changed, altered, or removed to allow individual users to execute root commands without being individually tracked or logged

QUIZ 5

1. Name the four types of evidence generally required.2. If you cannot implement a control you will fail the

audit. True/False?3. Compensating controls are _________ based and

must be accepted by ___________________.4. When designing a compensating control you must

always consider the ____________ objective.5. If I just nod once and a while, this guys actually

thinks I’m listening to him. True/False.

Project Management

MILESTONES

• Risk based prioritisation of implementation of the controls established by card brands

• Milestone 1 – identify what you have, where you have it and write policies to protect it.

• Milestone 2 – Network integrity• Milestone 3 – Code integrity• Milestone 4 – Logs & records• Milestone 5 – Incidents• Miles 6 – Auditing & testing

TIMELINES

• Missed deadline • Milestones 1-4 • Validation• SAQ• AoC to Acquirer • Annual Recertification

HOW WILL YOU GET THERE?

By starting and maintaining momentum! Document everything Monthly Acquirer reports Quick resolution of questions Compensating controls Site visits – practice audits Disseminating information

2 WORDS

Due diligence

The Messages

INTENT

Minimise risk to card holder data

Give PCI a

Chance!

BUSINESS MESSAGES

Card brand service requirements

Regulatory requirement

Losses impact our clients

Lost client confidence = Lost £

System down time = Lost £

Repair costs = Lost £

Data theft & fraud = Lost £

Reputation losses = Lost £

Fines = Lost £

EMPLOYEE

Security of our customer credit card data is critical to our mission.

We’ve implemented a detailed security program to protect this data.

Security is your responsibility. Security is everyone’s responsibility. Failure to meet this responsibility… We need your help and suggestions.

PARTNER

Protection of our customer data is mission critical to us. We have implemented a PCI DSS compliance program and are

pending formal certification. Regulatory compliance is a shared responsibility. Connectivity to our systems require compliance to PCI DSS controls as

a condition of contract. How can we help you?

CUSTOMER

We are implementing a PCI DSS compliance program and are pending formal certification.

We require all of our partners and suppliers to meet PCI DSS controls We have implemented a rigorous security testing program to ensure

the security integrity of our systems. Protection of your personnel data is critical to our business. If you have any question regarding our policies – do not hesitate to

contact us.

LAST QUIZ

1. Name a business message.2. Name a employee message.3. Name a client message.4. Name a partner message.5. Name all five members of the original Jackson 5.

The Close

IF NOTHING ELSE, REMEMBER

PCI DSS is a “risk management framework”

Implementation does not guarantee security

A framework only serves to identify, minimise and manage the risk of compromise.

At the day’s end - You still own the risk.

Identify

Minimise

Manage

A DIFFERENT PERSPECTIVE FROM:

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