Info Security & PCI(original)
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  • 1. Skeletal Elements of your Organization’s IT Systems Deter, Detect and Defend Against Data Breaches Information Security Program & Payment Card Industry Data Security (PCI DSS) Compliance for Your Business
  • 2. Security and Compliance Not Synonymous
      • Regulatory Compliance helps to improve Security
      • Improved Security helps to achieve Compliance
  • 3. 77 Million Users 10 Million Credit Card Compromised Accounts Losses ??? Millions of Names and Email Addresses of over 2,500 Major Companies Consequences??
  • 4. 94 Million Compromised Accounts 83 Million Dollars in Losses 4 Million Compromised Accounts 100’s of Compromised Accounts 50,000+ Credit Card Transactions Processed Yearly 20,000+ Credit Cards Numbers
  • 5. The High Cost of Data Breaches Average Cost Per Record Breached $204 Average Cost Per Breach $6.75 million Range of Total Cost Per Breach $750,000 to almost $31 million Source: Ponemon Institute, Fourth Annual Cost of Data Breach Study, January 2009
  • 6. Essentials Elements of a Successful Information Technology Security Program
  • 7. COBIT Standards Risk Assessment
      • Control Objectives for Information and related Technology (COBIT) is a set of best practices (framework) for information (IT) management created by the Information Systems Audit and Control Association (ISACA), and the IT Governance Institute (ITGI) in 1996.
      • Proactively identify IT related risks that require mitigation strategies, including anticipating future regulatory and external reporting expectations.
      • Aid in the overall IT Governance Activities and support the business’s operational risk initiatives.
  • 8.
      • Sound business decisions are based on timely, relevant and concise information.
      • Decision making is more effective because COBIT aids management in:
        • Defining a Strategic IT Plan
        • Defining the Information Architecture
        • Acquiring the necessary IT hardware and software to execute an IT strategy
        • Ensuring Continuous Service (BCP/DR)
        • Monitoring the Performance of the IT systems
        • Provides a foundation upon which IT related Decisions and Investments can be based
      • COBIT Executive Summary consists of an Executive Overview which provides a thorough awareness and understanding of COBIT's key concepts and principles.
    Management Benefits
  • 9.
      • Helps identify IT control issues within a company’s IT infrastructure
      • Corroborate their audit findings
      • COBIT is the framework used by most companies to comply with Sarbanes-Oxley.
    Auditors Benefits
  • 10.
      • Assurance that the IT applications that aid in the gathering, processing, and reporting of information comply with a recognized standard
      • Implies controls and security are in place to govern the IT processes
    End Users Benefits
  • 11. COBIT's Four Domains
      • Planning and Organization
      • Acquisition and Implementation
      • Delivery and Support
      • Monitoring
  • 12. Plan and Organize
      • Covers the use of technology and how best it can be used in a company to help achieve the company’s goals and objectives.
      • Highlights the organizational and infrastructural form IT is to take in order to achieve the optimal results and to generate the most benefits from the use of IT.
  • 13. Control Objectives for the Planning & Organization Domain PO1 Define a Strategic IT Plan PO2 Define the Information Architecture PO3 Determine Technological Direction PO4 Define the IT Processes, Organization & Relationships PO5 Manage the IT Investment PO6 Communicate Management Aims & Direction PO7 Manage IT Human Resources PO8 Manage Quality PO9 Assess and Manage IT Risks PO10 Manage Projects
  • 14. Acquire and Implement
      • Identifying IT requirements, Acquiring the Technology, and Implementing it within the company’s current business processes.
      • Addresses the development of a maintenance plan that a company should adopt in order to prolong the life of an IT system and its components.
  • 15. Control Objectives for the Acquire & Implement Domain AI1 Identify Automated Solutions AI2 Acquire and Maintain Application Software AI3 Acquire and Maintain Technology Infrastructure AI4 Enable Operation and Use AI5 Procure IT Resources AI6 Manage Changes AI7 Install and Accredit Solutions and Changes
  • 16. Delivery and Support
      • Execution of the applications within the IT system
      • The support processes that enable the effective and efficient execution of the IT systems
      • Support processes include security issues and training
  • 17. Control Objectives for the Delivery & Support Domain DS1 Define and Manage Service Levels DS2 Manage Third-party Services DS3 Manage Performance and Capacity DS4 Ensure Continuous Service DS5 Ensure Systems Security DS6 Identify and Allocate Costs DS7 Educate and Train Users DS8 Manage Service Desk and Incidents DS9 Manage the Configuration DS10 Manage Problems DS11 Manage Data DS12 Manage the Physical Environment DS13 Manage Operations
  • 18. Monitor and Evaulate
      • Deals with a company’s strategy in assessing the needs of the company and whether or not the current IT system still meets the objectives for which it was designed and the controls necessary to comply with regulatory requirements
      • Covers the issue of an independent assessment of the effectiveness of IT system in its ability to meet business objectives and the company’s control processes by internal and external auditors.
  • 19. Control Objectives for the Monitor & Evaluate Domain ME1 Monitor and Evaluate IT Processes ME2 Monitor and Evaluate Internal Control ME3 Ensure Regulatory Compliance ME4 Provide IT Governance
  • 20. Further Information: Information Systems Audit and Control Association (ISACA) http://www.isaca.org
  • 21. Annual Security Reporting
      • Introduction
        • Brief Synopsis of IT Security Yearly Activities
      • IT Security Activities
        • Policy/Standards Developments
        • Security Hardware and/or Software Implementations
      • Next Year’s IT Security Goals
      • COBIT Internal Risk Assessment
  • 22. Information Security Policy
      • Purpose
      • Objectives
      • Development and Implementation
      • Responsibility
      • Assessment and Management of Risk
      • Protection and Destruction of Sensitive Information
      • Monitoring, Testing & Updating of the Information Security Program
      • Monitoring of the Information Security Program
      • Overseeing Service Provider Arrangements
      • Annual Status Reporting and Policy Review
  • 23. Safeguarding Customer Information Policy
      • Policy Statement
      • Statement of Responsibilities
      • Computer Security
      • Physical Security
      • Copyrights and License
      • Monitoring
      • Violations
  • 24. Access Control Policy
      • User Access Management
      • Access Control Rules
      • Access Control Request Form
      • File System Control
      • Login Banner Notices
  • 25. Data Classification, Retention and Disposal Policy
      • Sensitivity Guidelines
      • Sensitive Information Retention & Disposal Guidelines
      • Credit Card Information Retention & Disposal Guidelines
  • 26. Intrusion Response Plan
      • Incident Severity
      • Incident Declaration
      • Document Recovery Steps
      • Analyze the Intrusion
      • Recover from the Intrusion
      • Intrusion Response Checklist
  • 27.
      • Customer Notice
      • Incident Declaration
      • Response Program
      • Recovery Steps
      • Sample Call Staff Instructions
      • Sample Call Staff Telephone Script Instructions
      • Customer Call Record Form
      • Suggested Communication to Regulators
      • Sample Customer Notification Letter
      • Identity Theft Bureaus & Agencies
      • Assessment of Unauthorized Access to Sensitive
      • Customer Information
      • Incident Response Log
    Unauthorized Access to Customer Information Plan
  • 28. Additional Items
      • Password Policy
        • Compliance Requirements
        • Password Integrity Guidelines
        • Password Protection Standards
        • Employee Acknowledgment
      • Vendor Management Program
        • Risk Assessment & Mitigation
        • Request for Proposal
        • Due Diligence
        • Implementation
  • 29. Further Information & Sample Polices/Guidelines: Systems And Network Security http://www.sans.org National Institute of Standards and Technology (NIST) www.nist.gov
  • 30. Payment Card Industry Data Security (PCI DSS) Compliance for Your Business
  • 31. A Security Breach and Subsequent Compromise of Cardholder Data could have far-reaching Consequences for Your Business including:
      • Regulatory Notification Requirements
      • Loss of Reputation
      • Loss of Customers
      • Potential Financial Liabilities (Regulatory and Other Fines and Fees)
      • Litigation
  • 32. Compliant Organizations Experience Fewer Breaches
      • 32% of Compliant Organizations Never Had a Breach vs. 12% of Non Compliant Organizations
      • 69% of Compliant Organizations Reported at Least One Breach vs. 88% of Non Compliant Organizations
  • 33. We all can help to Deter, Detect and Defend against ID Theft with these 5 easy steps: Take Stock – Know Where the Info Is Scale Down – Keep Only What is Needed Lock It – Protect the Info We Do Keep Pitch It – Properly Dispose of What We Don’t Plan Ahead – Create a Plan to Response to a Breach
  • 34. does not manage compliance programs and does not impose any consequences for non-compliance. may have their own compliance initiatives, including financial or operational consequences to certain businesses that are not compliant.
  • 35. The Road to PCI DSS Compliance is dependent on the Merchant Level & Self Assessment Questionnaire (SAQ) Validation Types
  • 36. Merchant Levels based on Credit Card Transactions Processed
      • Level 1 – Over 6,000,000 per year
      • Level 2 – 1,000,000 to 6,000,000 per year
      • Level 3 – 20,000 to 1,000,000 per year
      • Level 4 – Fewer than 20,000 per year
  • 37. Self Assessment Questionnaire (SAQ) Validation Types
  • 38. SAQ A
      • Card Not Present Merchants
      • All cardholder data functions outsourced
      • Never applies to face to face merchants
      • 13 Questions & Attestation
  • 39. SAQ B
      • Imprint Only Merchants
      • No electronic cardholder data storage
      • Standalone dialout terminal merchant with no date storage
      • 29 Questions & Attestation
  • 40. SAQ C-VT
      • Merchants with web based virtual terminals
      • No electronic cardholder data storage
      • 51 Questions & Attestation
  • 41. SAQ C
      • Merchants with Payment Applications connected to Internet
      • No electronic cardholder data storage
      • 40 Questions & Attestation
  • 42. SAQ D
      • All Merchants not included in other SAQ descriptions
      • All service providers defined by payment brand as eligible to complete a SAQ
      • 288 Questions & Attestation
  • 43. Maintain Information Security Policy Requirement 12 SAQ A,B,C,D Regularly Test Security Systems/Processes Requirement 11 SAQ C,D Track & Monitor Access to Network Resources & CHD Requirement 10 SAQ C,D Restrict Physical Access to CHD Requirement 9 SAQ A,B,C,D Assign Unique ID for each person w/ computer access to CHD Requirement 8 SAQ C,D Restrict CHD Access to Business Need-to-Know Requirement 7 SAQ B,C,D Develop & Maintain Secure Systems/Applications Requirement 6 SAQ C,D Use & Regularly Update Anti-Virus Software Requirement 5 SAQ C,D Encrypt Transmission of CHD across Public Networks Requirement 4 SAQ B,C,D Protect Stored CHD Requirement 3 SAQ B,C,D Change All Defaults Passwords & Security Parameters Requirement 2 SAQ C,D Install & Maintain Firewall Configuration to protect CHD Requirement 1 SAQ C,D Security Requirements for PCI DSS Compliance
  • 44. Prioritized Approach to Pursue PCI DSS Compliance
      • 1. Remove Sensitive Authentication Data and Limit Data Retention (Requirements 1,3,9)
      • 2. Protect the Perimeter, Internal and Wireless Networks (Requirements 1,2,4,5,11,12)
      • 3. Secure Payment Card Applications (Requirements 2,6)
      • 4. Monitor and Control Access to Systems
    • (Requirements 7,8,10,11)
      • 5. Protect Stored Cardholder Data (Requirements 3,9)
      • 6. Finalize remaining Compliance Efforts and Ensure all Controls are in Place (Requirements 1,6,10,11,12)
  • 45. Prioritized Approach to Pursue PCI DSS Compliance Tool https://www.pcisecuritystandards.org/documents/Prioritized_Approach_PCI_DSS_version1_2.xls
  • 46. PCI Compliance in its simplest form is; if you don’t need the cardholder data - then don’t store it, if you store it, you must protect it.
  • 47. Further Information on
      • Complete PCI DSS Specification
      • Prioritized Approach Guidance & Tool
      • Other Supporting Tools and Documentation
    • http://www.pcisecuritystandards.org
  • 48. Questions??