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Risk Factory: PCI - The Essentials

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Risk Factory: PCI - The Essentials

  1. 1. PCI: The Essentials
  2. 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. www.riskfactory.com
  3. 3. 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
  4. 4. The Standard
  5. 5. 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.
  6. 6. 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)
  7. 7. The Standard
  8. 8. Applies to:• Systems that store, process or transmit cardholder data• Systems that connect to themCompliance is mandatory – Enforced through merchant services agreements
  9. 9. 6 Goals, 12 RequirementsThe PCI DSS standard is based upon the following 6 core principles and 12 requirements: 264 controls requirementsBuild and Maintain a Secure NetworkRequirement 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 DataRequirement 3: Protect stored cardholder data.Requirement 4: Encrypt transmission of cardholder data across open, public networks.Maintain a Vulnerability Management ProgramRequirement 5: Use and regularly update anti-virus software.Requirement 6: Develop and maintain secure systems and applications.Implement Strong Access Control MeasuresRequirement 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 NetworksRequirement 10: Track and monitor all access to network resources and cardholder data.Requirement 11: Regularly test security systems and processes.Maintain an Information Security PolicyRequirement 12: Maintain a policy that addresses information security
  10. 10. 264 ControlsRequirement 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.
  11. 11. The Structure
  12. 12. Cardholder Data? Magnetic stripe Chip Card account number Expiry dateCard (PAN) number
  13. 13. Controls-2-Data
  14. 14. Scoping
  15. 15. 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.
  16. 16. Quiz 11. 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?
  17. 17. The Players
  18. 18. The Players Card Brands PCI Council Acquirers QSA ASV Merchants Service Providers
  19. 19. Relationships Matrix Acquirer Merchant Service Provider Cardholder
  20. 20. Concerns & Consequences Cardholder Data Cardholder Targeted Victimized Government Media Regulatory Intervention Scrutiny Enforcement
  21. 21. Cardholder Data Exposure Service Service Provider Provider Payment Application
  22. 22. 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.
  23. 23. 24
  24. 24. Quiz 21. 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?
  25. 25. Compliance Process
  26. 26. Process
  27. 27. Key Documentation Card Data Security Policy Comprehensive Network Diagram Evidence 3rd Party Agreements End User Agreements Security Vulnerability Scan Reports Security Penetration Reports
  28. 28. 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
  29. 29. Process – not a checklist
  30. 30. • Identify• Minimise• Manage
  31. 31. Quiz 31. 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
  32. 32. Exercise
  33. 33. 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?
  34. 34. The Policies
  35. 35. Framework
  36. 36. Policies1. 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 action4. REVIEW, UPDATES & MAINTENANCE • Annual • 30 days after significant changes5. EXCEPTIONS • Require Compliance Manager’s prior approval6. PROGRAM MANAGEMENT
  37. 37. Policies6.1 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 Compliance6.2 INFORMATION SECURITY RISK ASSESSMENTS• Annually• Prior to significant changes6.3 MINIMISE HOLDINGS6.4 CARD DATA ASSET REGISTER• Maintain current list of all devices hosting card data6.5 ASSET CLASSIFICATION• Hardware & software marked “Company Confidential”
  38. 38. Policies6.6 EMPLOYEE CHECKS• Staff with access to card data = criminal & credit checks6.7 SECURITY TRAINING• Initial• Annual update6.8 3rd PARTY CONNECTIVITY AGREEMENTS• Condition of connectivity6.9 3rd PARTY COMPLIANCE6.10 3rd PARTY AUDITS• Initial• Annual verification
  39. 39. Policies6.11 NETWORK SECURITY VULNERABILITY SCANNING• Done quarterly – Pass – submitted to Acquirer6.12 NETWORK SECURITY PENETRATION TESTING• Annually• After significant changes6.13 APPLICATION SECURITY PENETRATION TESTING• Applies to all application process/store/transmit• Conducted prior to launch• After significant changes• Annually7. SYSTEM SECURITY7.1 FIREWALL & ROUTER CONFIGURATIONS• As stated in Annex
  40. 40. Policies7.2 PASSWORDS & SECURITY ADMINISTRATION• Vendor accounts & defaults removed• Admin access encrypted• Configuration security build standards7.3 CARD DATA STORAGE• Minimise!• Data Retention Policy• Do not store authentication data7.4 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 data7.6 SYSTEM MONITORING • Quarterly testing for wireless - Implement IDS - File integrity monitoring
  41. 41. Policies8. APPLICATION SECURITY• Software security development lifecycle procedures• Change control procedures as detailed in Annex• Patches• Process to keep up to date with new application threats9. LOGS & RECORDS• System logs as detailed in Annex10. SYSTEM USER SECURITY• Need to know• Password• Screensaver, lock outs11. PHYSICAL ACCESS CONTROLS • Facility access control, locks alarms • Visitor badging • Protection of hard copy card data
  42. 42. Quiz 41. 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.
  43. 43. The Controls
  44. 44. ControlsRequirement 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.
  45. 45. Evidence• Types • Observation (configuration or process) • Documentation • Interview • Technical (monitoring of network traffic)• Required for each and every control !
  46. 46. Controls ExampleRequirement 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)
  47. 47. Policy ExampleRequirement 12: Maintain a policy that addresses information security for employeesand 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)
  48. 48. 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
  49. 49. Compensating Controls  Information Required Explanation1. 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 privileges1. 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
  50. 50. Quiz 51. 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.
  51. 51. ProjectManagement
  52. 52. 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
  53. 53. Timelines• Missed deadline• Milestones 1-4• Validation• SAQ• AoC to Acquirer• Annual Recertification
  54. 54. 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
  55. 55. 2 Words Due diligence
  56. 56. The Messages
  57. 57. Intent Give PCI a Chance! Minimise risk to card holder data
  58. 58. 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 £
  59. 59. 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.
  60. 60. 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?
  61. 61. 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.
  62. 62. Last Quiz1. 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.
  63. 63. The Close
  64. 64. 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.
  65. 65. • Identify• Minimise• Manage
  66. 66. 26 Dover Street London United Kingdom +44 (0)20 3170 8955+44 (0)20 3008 6011 (fax) 67

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