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.
www.riskfactory.com

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.

ADC
Industry Forensics Security
Best Results
Practices Scans
Advisory On Site
Board PCI Data Security Audits
Standard
Self-
Community Assessment
Meeting
Approved Questionnaire
Proactive
feedback Scanning
from QSAs, Vendors
ASVs and (ASVs) and Qualified
POs Security Assessors
(QSAs)

The Standard

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 Requirements
The PCI DSS standard is based upon the following 6 core principles and 12 requirements: 264 controls
requirements
Build and Maintain a Secure Network
Requirement 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 Data
Requirement 3: Protect stored cardholder data.
Requirement 4: Encrypt transmission of cardholder data across open, public networks.
Maintain a Vulnerability Management Program
Requirement 5: Use and regularly update anti-virus software.
Requirement 6: Develop and maintain secure systems and applications.
Implement Strong Access Control Measures
Requirement 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 Networks
Requirement 10: Track and monitor all access to network resources and cardholder data.
Requirement 11: Regularly test security systems and processes.
Maintain an Information Security Policy
Requirement 12: Maintain a policy that addresses information security

264 Controls
Requirement 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

Cardholder Data?
Magnetic stripe
Chip
Card account number
Expiry date
Card (PAN) 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
Acquirer
Merchant Service Provider Cardholder

Concerns & Consequences
Cardholder Data Cardholder
Targeted Victimized
Government Media Regulatory
Intervention Scrutiny Enforcement

Cardholder Data Exposure
Service Service
Provider Provider
Payment
Application

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.

24

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?

Compliance
Process

Process

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

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 HOLDINGS
6.4 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 COMPLIANCE
6.10 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 SECURITY
7.1 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

Policies
8. 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)

Policy Example
Requirement 12: Maintain a policy that addresses information security for employees
and contractors.
12.8.4 Maintain a program to monitor service providers’ PCI DSS compliance status.
Observation (configuration)
 Observation (process)
 Documentation (policy)
 Interview (receptionist)
 Technical (none)

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 Explanation
1. Constraints List constraints precluding compliance with the original Company XYZ employs stand-alone Unix Servers without LDAP. As such, they each
requirement. 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 The objective of requiring unique logins is twofold. First, it is not considered acceptable
objective met by the compensating control. 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 Additional risk is introduced to the access control system by not ensuring all users have a
original control. unique ID and are able to be tracked.
1. Definition of Compensating Controls Define the compensating controls and explain how they Company XYZ is going to require all users to log into the servers from their desktops using
address the objectives of the original control and the the SU command. SU allows a user to access the “root” account and perform actions
increased risk, if any. 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 Company XYZ demonstrates to assessor that the SU command being executed and that
and tested. 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 Company XYZ documents processes and procedures to ensure SU configurations are not
compensating controls. 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
Give
PCI
a
Chance!
Minimise risk to card holder data

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

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London
United Kingdom
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+44 (0)20 3008 6011 (fax)
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