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PCI: How to break the piggy bank!

For any company, merchants included, who haven’t been meeting the PCI Data Security Standards, I have some bad news: you’re about to spend at least twice the money you never spent on security and privacy in the first place.

If you purchased bargain basement discounted Point-of-Sale systems, you’re in for a surprise courtesy of Visa’s Application Securityrequirements. In fact PCI has adopted these standards and will begin enforcing them in 2008 and 2009. The requirements associated with the Application Security portion will target all levels, not just the top tier.

If you lucked out in the PCI Compliance lottery by outsourcing everything to do with credit card data, that outsourcing is likely to get expensive as the outsourcer will likely pass those costs on to its customers.

If you seriously need to get up to speed quickly, I would advise following the steps outlined in a recent SearchSecurity Article. I’ve numbered the steps as Mike Rothman presented them in the article:

  1. First, pick off the low-hanging fruit such as Requirement 1, which is to have a firewall to protect cardholder data, and Requirement 5, which mandates the use and updating of antivirus software.
  2. Requirement 2, which is to change default passwords and other security parameters.
  3. Also take a look at Requirement 4, which requires encryption to protect cardholder data that is sent over open networks. Simply using SSL allows an organization to check the box on that requirement.
  4. After picking off the simplest stuff, address the requirements that can be difficult or nebulous, like Requirement 3 to protect stored cardholder data, or Requirement 6 to develop and maintain secure systems and applications.

The last thing you want to do is try PCI Compliance blind-folded. You and/or your team need to understand the requirements before you attempt to comply and before you bring in any outside consultant to document data flows or perform site assessments because it is easy to go broke and/or break the company complying with PCI.

PCI Ramblings

Practicing security is not the art it use to be. I read an article on Ambersail’s blog that reminded me of the youth soccer team I used to coach.

In particular, I was struck by the similarity between people’s attitude towards security, and a group of kids playing football. Somebody kicks the ball, and the other 21 players chase after it. No strategy, no gameplan, no big picture. Everyone likes to think they have the answer (me included, of course) and that’s what they pitch in with. But in the end, it’s just a single kick – and off we all go again, chasing the ball. [Ambersail Blog]

The post was in response to the Fasthost breach, reported in The Register, but what stuck me as I read the Ambersail post was just how true the point was and how the 7-8 year old soccer kids I coached a few years back all blindly followed that soccer ball around and would rarely get in front of it to stop the ball. Comments and suggestions can be helpful after a breach but they’re more powerful BEFORE the breach.

It’s been said hindsight is 20/20; security is no different. What should and shouldn’t be done from a security perspective becomes painfully clear after a breach happens. The same is true for almost any operational environment where something has gone amiss.

Rarely are there huge “Ah hah!” moments in our day and age, where the lessons learned following an incident or breach are new discoveries. I’ve said it before, the security landscape ends up being the sum of the compromises and consessions a company makes.

Most often the very things that lead to breaches, compromises, or even operational failures are the result of business decisions made in order to reduce cost, lower support impacts, be user firendly, or reduce operational burdens associated with observing appropriate security and privacy controls. Obviously this doesn’t account for 100% of security breaches, but certainly more than half of reported breaches could have been prevented by proper security controls.

This is one reason why security requirements are showing up everywhere and another reason why, just like my soccer kids, everyone will continue chasing the ball no matter where it goes and breaches will continue until someone gets in front of the ball!