PCI Myths


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This presentation covers PCI DSS-related myths and misconceptions that are common among some merchants and other organizations dealing with PCI DSS challenges. Mistakes related to technical and process side of PCI, self-assessment and audits as well as PCI validation requirements will be discussed. The information will be useful to all merchants dealing with credit card information and thus struggling with PCI DSS mandates.

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PCI Myths

  1. 1. Technology Briefing Series PCI Myths: Common Mistakes and Misconceptions About PCI Anton Chuvakin
  2. 2. Agenda • What is PCI DSS? • When does PCI DSS apply? • PCI DSS myths • Approach to PCI • PCI implementation mistakes • Life after audit: compliance vs validation • Conclusions 2
  3. 3. What is PCI DSS v 1.2 PCI DSS is based on basic data security practices! • Install and maintain a firewall confirmation to protect data • Build and Maintain a Do not use vendor-supplied defaults for system passwords Secure Network and other security parameters • Protect stored data • Protect Cardholder Data Encrypt transmission of cardholder data and sensitive information across public networks • Use and regularly update anti-virus software Maintain a Vulnerability Management • Program Develop and maintain secure systems and applications • Restrict access to data by business need-to-know • Implement Strong Access Control Assign a unique ID to each person with computer access Measures • Restrict physical access to cardholder data • Track and monitor all access to network resources and Regularly Monitor and cardholder data • Test Networks Regularly test security systems and processes • Maintain an Information Security Maintain a policy that addresses information security Policy
  4. 4. When PCI Applies… “PCI DSS compliance includes merchants and service providers who accept, capture, store, transmit or process credit and debit card data.” 4
  5. 5. PCI Certification Merchant & Service Provider Levels 5
  6. 6. M1 - PCI just doesn’t apply to us … Myth: PCI just doesn’t apply to us, because… • “… we are small, a University, don’t do e-commerce, outsource “everything”, not permanent entity, etc” Reality: PCI DSS DOES apply to you if you “accept, capture, store, transmit or process credit and debit card data”, no exceptions! At some point, your acquirer will make it clear to you! 6
  7. 7. M2 - PCI is confusing Myth: PCI is confusing and not specific! • “We don’t know what to do, who to ask, what exactly to change” • “Just give us a checklist and we will do it. Promise!” Reality: PCI DSS documents explain both what to do and how to validate it; take some time to read it. Whether you get it now, you will need to do it later. Otherwise, data and $ loss is yours! 7
  8. 8. M3 - PCI is too hard Myth: PCI is too hard … • “… too expensive, too complicated, too burdensome, too much for a small business, too many technologies or even unreasonable” Reality: PCI DSS is basic, common sense, baseline security practice; it is only hard if you were not doing it before. It is no harder than running your business or IT – and you’ve been doing it! 8
  9. 9. M4 - Breaches prove PCI irrelevant Myth: Recent breaches prove PCI irrelevant • “We read that ‘media and pundits agree – massive data losses “prove” PCI irrelevant’” Reality: Data breaches prove that basic PCI DSS security is not enough, but you have to start from the basics. PCI is actually easier to understand than other advanced security and risk matters. Start there! 9
  10. 10. M5 – PCI is Easy: Just Say “YES” Myth: PCI is easy: we just have to “say Yes” on SAQ and “get scanned” • “What do we need to do - get a scan and answer some questions? Sure!’” • “PCI is about scanning and questionnaires” Reality: Not exactly - you need to: a) Get a scan – and then resolve the vulnerabilities found b) Do the things that the questions refer to – and prove it c) Keep doing a) and b) forever! 10
  11. 11. M6 – My tool is PCI compliant Myth: My network, application, tool is PCI compliant • “The vendor said the tool is ‘PCI compliant’” • “My provider is compliant, thus I am too” • “I use PA-DSS tools, thus I am PCI OK” Reality: There is no such thing as “PCI compliant tool, network”, PCI DSS compliance applies to organizations. PCI DSS combines technical AND process, policy, management issues; awareness and practices as well. 11
  12. 12. M7 – PCI Is Enough Security Myth: PCI is all we need to do for security • “We are secure, we got PCI!” • “We worked hard and we passed an ‘audit’; now we are secure!” Reality: PCI is basic security, it is a necessary baseline, but NOT necessarily enough. PCI is also about cardholder data security, not the rest of private data, not your intellectual property, not SSNs, etc. It also covers confidentiality, and NOT integrity and availability of data. There is more to security than PCI! 12
  13. 13. M8 – PCI DSS Is Toothless Myth: Even if breached and also found non-compliant, our business will not suffer. • “We read that companies are breached and then continue being profitable; so why should we care?” Reality: Possible fines + lawsuits + breach disclosure costs + investigation costs + CC rate increases + contractual breaches + cost of more security measures + cost of credit monitoring = will you risk ALL that? 13
  14. 14. Summary: Eight Common PCI Myths 1. PCI just doesn’t apply to us, because… 2. PCI is confusing and not specific! 3. PCI is too hard 4. Recent breaches prove PCI irrelevant 5. PCI is easy: we just have to “say Yes” on SAQ and “get scanned” 6. My network, application, tool is PCI compliant 7. PCI is all we need to do for security! 8. Even if breached and then found non- compliant, our business will not suffer 14
  15. 15. Your Approach To PCI DSS 1. Understand your merchant level (1-4) 2. Review the applicable requirements 3. Identify the gap between your current and required state 4. Implement changes to technology and policies! 5. Validate requirements and attest to it (via SAQ or QSA) 6. Key: continue to maintain secure-thus-compliant state! “Businesses that are compliant with PCI standards have never been breached. Victims may have attained compliance certification at some point, but none has been in compliance at the time of a breach.” Bob Russo, GM of PCI Security Standards Council 15
  16. 16. Select PCI Implementation Mistakes 1. Start “closing the gap” before limiting the scope Solution: Segment the payment network off, make it smaller! 2. Stay in technology realm Solution: Think process and policies; only they will allow for continuous compliance, not what you deploy today 3. Have “audit mentality”, not “risk mentality” Solution: Approach PCI as a risk-mitigation effort, not a “checklist”; you are not “done” when QSA leaves 4. Chose an “easy” QSA and “subpar” ASV Solution: if you do, the loss is still yours; don’t! 16
  17. 17. Continuous Compliance vs Validation Reminder: PCI DSS compliance does NOT end when a QSA leaves or SAQ is submitted. What to do “after your QSA leaves”? • Use what you built for PCI to reduce risk • “Own” PCI DSS; make it the basis for your policies • Think beyond credit card data and grow your security! Note: a good QSA will check whether you are “wired” for continuous compliance. Pick one of that sort! 17
  18. 18. Conclusions and Action Items 1. PCI is common sense, basic security; stop complaining about it - start doing it! 2. After validating that you are compliant, don’t stop: continuous compliance AND security is your goal, not “passing an audit.” 3. Develop “security and risk” mindset, not “compliance and audit” mindset. 18
  19. 19. PCI Compliance for Dummies More information? Read “PCI Compliance for Dummies” Get as much information as you can about PCI and how it relates to your organization! 19
  20. 20. Q&A Thank You anton@qualys.com 20 20