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PCI DSS-based Security: Is This For Real? by Dr. Anton Chuvakin

PCI DSS-based Security: Is This For Real? by Dr. Anton Chuvakin



PCI DSS-based Security: Is This For Real? Using PCI DSS as A Foundation for Your Security Program

PCI DSS-based Security: Is This For Real? Using PCI DSS as A Foundation for Your Security Program



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  • http://www.pciknowledgebase.com/index.php?option=com_mtree&task=viewlink&link_id=1366&Itemid=0As a banker who has been involved in audit and risk management for 20+ years, I have a beef with PCI. Too many have lost sight of goal which is to reduce the risk of security breaches and card fraud. Assessors often just focus on the words in the standard. They do not understand WHY the standard was written, or the risk built into it. We have removed the acceptance of risk as an option by insisting on 100% compliance. That was not the intent.
  • “The best method to protect data from hackers is to delete it”PCI Compliance book http://www.pcicompliancebook.info/

PCI DSS-based Security: Is This For Real? by Dr. Anton Chuvakin PCI DSS-based Security: Is This For Real? by Dr. Anton Chuvakin Presentation Transcript

  • PCI DSS-based Security: Is This For Real?Using PCI DSS as A Foundation for Your Security Program
    Dr. Anton Chuvakin
    Author of “PCI Compliance”
    Security Warrior Consulting
    Secure 360, Minneapolis, MN
    May 2010
  • Inspiration….
    “Too many have lost sight of goal which is to reduce the risk of security breaches and card fraud. Assessors often just focus on the words in the standard. They do not understand WHY the standard was written, or the risk built into it. “
    PCI Knowledge Base by late David Taylor
  • “PCI Is The Devil !!!”
  • Outline
    What is PCI DSS? Why it is here?
    PCI DSS as a security framework
    PCI DSS as a data security framework
    Starting from PCI: how to do it?
    Risks and pitfalls
  • What is PCI DSS or PCI?
    Payment Card Industry Data Security Standard
    Payment Card =
    Payment Card Industry =
    Data Security =
    Data Security Standard =
  • PCI Data Security Standard
    PCI Council publishes PCI DSS –Data Security Standard
    Outlined the minimumdata security protections measures for payment card data.
    Defined Merchant & Service Provider Levels, and compliance validation requirements.
    Left the enforcement to card brands (Council doesn’t fine anybody!)
    Key point: PCI DSS (document) vs PCI (validation regime)
  • PCI Game: The Players
    PCI Security Standards Council
  • My Data – Their Risk!?
    • Install and maintain a firewall confirmation to protect data
    • Do not use vendor-supplied defaults for system passwords and other security parameters
    Build and Maintain a Secure Network
    • Protect stored data
    • Encrypt transmission of cardholder data and sensitiveinformation across public networks
    Protect Cardholder Data
    • Use and regularly update anti-virus software
    • Develop and maintain secure systems and applications
    Maintain a Vulnerability Management Program
    • Restrict access to data by business need-to-know
    • Assign a unique ID to each person with computer access
    • Restrict physical access to cardholder data
    Implement Strong Access Control Measures
    • Track and monitor all access to network resources and cardholder data
    • Regularly test security systems and processes
    Regularly Monitor and Test Networks
    • Maintain a policy that addresses information security
    Maintain an Information Security Policy
    PCI Data Security Standard In-Depth
  • PCI DSS Coverage
    … in no particular order:
    Security policy and procedures
    Network security
    Malware protection
    Application security (and web)
    Vulnerability scanning and remediation
    Logging and monitoring
    Security awareness
  • PCI DSS With No Cards?
  • PCI Coverage: What Do We Learn?
    Focus: confidentiality credit of card data…
    … but not exactly: data avoidance is even better!
    Now …
    … a hard question: what is “a good security program”?
    What technology, processes, etc?
    What are the goals?
    What are the metrics?
  • Our Goals!
  • Holes?
    BIG HOLE#1 Everything availability
    “If your payment app blows up, it magically becomes ‘PCI compliant’” 
    HOLE #2 Everything productivity
    Spam, web filtering, client protection, etc
    HOLE #3 Card data discovery
    PCI assumes omniscient data owners…
  • Sidetrack: WTH is “Data Security”
    … back to
    If you router is 0wned, is data security still achieved?
    If a secondary system is compromised?
    QA machine?
    Public web server?
    Know any “data idiots?”
  • Pros and Cons
    Good coverage of many domains (tech and process)
    Useful focus on data elimination, app security and monitoring
    Detailed guidance available
    A lot of tools available to help
    Lacks complexity of ISO, NIST, etc
    • Does not start from policy (but you can!)
    • Holes!
    • Lack of logical structure (but Prioritized Approach is there)
    • Your risk not covered
    • “Kill the data” focus doesn’t apply to some
    • Measuring success?!
  • Pause…
    What do you think?
  • OK, Diving In…
  • Phase 1 Understanding
    Read PCI DSS and Prioritized Approach
    Organize into domains
    Split technology requirements from process/policy/procedure
    Mind the holes!
    Also: think about other regulations, e.g. breach disclosure laws
  • Holes? What Holes?
  • Phase 2 Plan
    Policy/process gap
    Technology gap
    Anything to buy? Build? Outsource?
    “Close the gap” strategy
    Guidance: PCI SSC “Prioritized Approach”
    “Reverse PCI”: start from Req 12 “Policy “
    Coordinate with stakeholders
  • Scope Explodes!
    Key lesson in PCI compliance:
    SHRINK THE SCOPE! “Drop the data”
    Here we expand the scope to all data and even all systems.
  • Phase 3 Do it!
    Following the prioritized plan, start building
    If under actual PCI regime, start from payment networks [of course!]
    Adjust! You are not “praying to PCI gods”
    Q: Can I use ISO27001 instead?
    A: Sure, but you would not be reading this if you had this choice!
  • Done?
  • Phase 4 Run it!
    Ongoing tasks in PCI:
  • Success? Success!!!
    Measure success
    Metrics system
    No assessment prep (no QSA) – but do self-assess! (INPUTS)
    Incident and loss reduction (OUTPUTS)
    Document – as if for QSA!
    “Compliance is validated security”
  • Key Issue
    Q: Which one of these guarantees that you will never suffer a motorcycle accident?
    A: Having “a helmet law” on the books
    B. Being aware of the above law
    C. Always wearing a basic helmet
    D. Always wearing an advanced, “market leading” helmet
  • Answer!
  • Why Are We Doing It?
    Risk of DEATH
    Risk of $60 fine?
  • Conclusions
    What we have achieved here?
    Likely, became PCI compliant
    Evaluated PCI as a foundation for security
    Built a security program
    Started operational processes
    Helped protect data, systems and other valuable information assets!
  • In Other Words…
    Every time you think “PCI DSS OR security,”
    god kills a kitten!
  • Questions?
    Dr. Anton Chuvakin
    Google Voice: 510-771-7106
  • Get “PCI Compliance” Book!
    Useful reference for merchants, vendors – and everybody else in “PCI realm”
    Book released Dec 2009
    Get two free chapters at
  • More on Anton
    NOW: consultanthttp://www.securitywarriorconsulting.com
    Book author: “Security Warrior”, “PCI Compliance”, “Information Security Management Handbook”, “Know Your Enemy II”, “Hacker’s Challenge 3”, etc
    Conference speaker: SANS, FIRST, GFIRST, ISSA, CSI, Interop, many, many others worldwide
    Standard developer: CEE, CVSS, OVAL, etc
    Community role: SANS, Honeynet Project, WASC, CSI, ISSA, OSSTMM, InfraGard, ISSA, others
    Past roles: Researcher, Security Analyst, Strategist, Evangelist, Product Manager
  • Security Warrior Consulting Services
    Logging and log management policy
    Develop logging policies and processes, log review procedures, workflows and periodic tasks as well as help architect those to solve organization problems
    Plan and implement log management architecture to support your business cases; develop specific components such as log data collection, filtering, aggregation, retention, log source configuration as well as reporting, review and validation
    Customize industry “best practices” related to logging and log review to fit your environment, help link these practices to business services and regulations
    Help integrate logging tools and processes into IT and business operations
    Content development
    Develop of correlation rules, reports and other content to make your SIEM and log management product more useful to you and more applicable to your risk profile and compliance needs
    Create and refine policies, procedures and operational practices for logging and log management to satisfy requirements of PCI DSS, HIPAA, NERC, FISMA and other regulations
    More at www.SecurityWarriorConsulting.com