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Risk Factory: PCI Compliance in the Cloud
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Risk Factory: PCI Compliance in the Cloud


Clearing the air.

Clearing the air.

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  • Give out cards
  • Oldest crime on record – not prostitution First recorded case of identity theft Bible: Genesis XXX


  • 1. PCI: Compliance in the Cloud
  • 2. 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.
  • 3. AgendaCloud Anatomy•Characteristics, Delivery & Deployment Models•Whats Different in the Cloud?•Security Challenges in the CloudPCI DSS•What is it?•Implementation Challenges•Cloud Compliance KeysCloudy QSA Advice•Clients•Vendors
  • 4. Cloud Security Visionary
  • 5. Both Sides Now "Rows and flows of angel hair And ice cream castles in the air And feather canyons everywhere Ive looked at clouds that way" Joni Mitchell
  • 6. Side 1 - Consumer
  • 7. Both Sides Now"But now they only block the sunThey rain and snow on everyoneSo many things I would have doneClouds got in my way " Joni Mitchell
  • 8. Side 2 - ServiceProviders
  • 9. Cloud Anatomy
  • 10. Cloud Benefit$
  • 11. Whats Different in theCloudSecurity Security ~ THEMOwnership Security ~ YOU SaaS Software as a Service IaaS PaaS Platform as a Service Infrastructure as a Service
  • 12. Whats Different in the CloudAccess Control
  • 13. Whats Different in the CloudVulnerability
  • 14. Most SignificantAccountability “Cloud” Provider Datacenter in London, U.K. Your Corporate Data? “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
  • 15. Cloudy Issues Confidentiality Availability Integrity Trust: Lack of transparency Trust: Identity management & access control Risk Management Liability Governance Compliance
  • 16. 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:
  • 17. Basic Misconceptions • "But its Cloud! How can you attack a Cloud?" • "Theres security in anonymity". • "Time sharing" with a new name & technology. Security Requirements Cloud Benefits
  • 18. Cloudy ThinkingSame as your existing server environment only virtualised and insomeone elses Data Centre running on Windows and Linux with Windows and Linux vulnerabilities
  • 19. Black Swan Sightings
  • 20. The StandardFirst published January 2005,V.1 released September 7,2006, the PCI DSS is a set ofcomprehensive requirementsfor securing payment data.V2 released November 2010.A multifaceted standard that includes requirements for security management, policies, procedures, network architecture, software design and other critical protective measures.
  • 21. Applicable• All systems that process, store or transmit credit or debit cardholder data• All systems that connect to them
  • 22. 6 Goals, 12 Requirements
  • 23. 264 Controls
  • 24. Specific Cloud Controls
  • 25. The PCI DSSImplementing the PCI DSS in the Cloud is like...
  • 26. 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
  • 27. Scoping is Everything
  • 28. Compliance Keys = Service Level Agreements = Compensating Controls
  • 29. SLA Amazon Web Services™ Customer Agreement7.2. Security. We strive to keep Your Content secure, but cannot guarantee thatwe 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 acknowledgethat you bear sole responsibility for adequate security, protection and backup ofYour Content and Applications. We strongly encourage you, where available andappropriate, to (a) use encryption technology to protect Your Contentfrom unauthorized access, (b) routinely archive Your Content, and (c) keep yourApplications or any software that you use or run with our Services current with thelatest security patches or updates. We will have no liability to you for anyunauthorized access or use, corruption, deletion, destruction or loss of any of YourContent or Applications. (2 February 2012)
  • 30. RememberSecurity Security ~ THEMOwnership Security ~ YOU SaaS Software as a Service IaaS PaaS Platform as a Service Infrastructure as a Service Amazon EC2 - Google AppEngine - Salesforce - IaaS PaaS SaaS
  • 31. Control Mapping Cloud Model Find the Gaps! Governance Model Applications SDLC, Binary Analysis, Scanners, WebApp Firewalls, Transactional Sec. Compliance Model Information DLP, CMF, Database Activity Monitoring, Encryption Management GRC, IAM, VA/VM, Patch Management, Configuration Management, Monitoring Network NIDS/NIPS, Firewalls, DPI, Anti-DDoS, QoS, DNSSEC, OAuth Trust Hardware & Software RoT & API’s Host-based Firewalls, HIDS/HIPS, Storage Integrity & File/log Management, Encryption, Masking Physical Physical Plant Security, CCTV, Guards
  • 32. Where Cannot Be Mapped• Conduct risk assessment• Identify unacceptable risks• Implement compensating controls! – Designed, accepted for the business – Must produce evidence – Accompanied by process
  • 33. Modelling Cloud Architecture Cloud Architecture Governance and Enterprise Risk Management Governance and Enterprise Risk Management Legal and Electronic Discovery Legal and Electronic Discovery Compliance and Audit Compliance and AuditOperating in the Cloud Governing the Cloud Information Lifecycle Management Information Lifecycle Management Portability and Interoperability Portability and Interoperability Security, Bus. Cont,, and Disaster Recovery Security, Bus. Cont,, and Disaster Recovery Data Center Operations Data Center Operations Incident Response, Notification, Remediation Incident Response, Notification, Remediation Application Security Application Security Encryption and Key Management Encryption and Key M anagement Identity and Access Management Identity and Access Management Virtualization Virtualization
  • 34. QSA Words of Wisdom
  • 35. QSA Client Advice "Never trust the vendor"
  • 36. QSA Client Advice• Dont 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 dont 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 companys 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 Acquirers buy in.• Get insurance.
  • 37. QSA Vendor Advice "Never trust the client"
  • 38. 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 cant 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
  • 39. "Ive looked at clouds from both sides now, from up and down, and still somehow, its clouds illusions I recall I really dont know all." Joni Mitchell
  • 40. 26 Dover Street London United Kingdom W1S 4LY +44 (0)20 3586 1025+44 (0)20 7763 7101(fax)