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Brian Pennington

A blog about Cyber Security & Compliance

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April 2012

Information Commissioner finally fines the NHS for a breach of the Data Protection Act

The Aneurin Bevan Health Board (ABHB) has become the first part of the NHS to be issued with a penalty (£70,000) for breaching the Data Protection Act.

The breach occurred when a consultant emailed a letter to a secretary for formatting, but did not include enough information for the secretary to identify the correct patient. The doctor also misspelt the name of the patient at one point, which led to the report being sent to a former patient with a very similar name.

The ICO’s investigation found that neither member of staff had received data protection training and that the organisation didn’t have adequate checks in place to ensure that personal information was sent to the correct person. These poor practices were also used by other clinical and secretarial staff across the organisation.

Stephen Eckersley, the ICO’s Head of Enforcement said:

“The health service holds some of the most sensitive information available. The damage and distress caused by the loss of a patient’s medical record is obvious, therefore it is vital that organisations across this sector make sure their data protection practices are adequate. 

“Aneurin Bevan Health Board failed to have suitable checks in place to keep the sensitive information they handled secure. This case could have been extremely distressing to the individual and their family and may have been prevented if the information had been checked prior to it being sent.

“We are pleased that the Health Board has now committed to taking action to address the problems highlighted by our investigation; however organisations across the health service must stand up and take notice of this decision if they want to avoid future enforcement action from the ICO.”

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PCI Point-to-Point Encryption Solution Requirements and Testing Procedures v1.1

The Payments Security Standards Council (PCI SSC) have released their solutions Requirements and Testing Procedures version 1.1 for Point-to-Point Encryption (P2PE).

The press release can be found here.

The main document is 210 pages long but for those who have looked into this before there is a short four page summary of changes from version 1.0 to version 1.1 here.

The document covers many things but the five main scope assessments for P2PE Solutions are

  1. Network Segmentation
  2. Third Parties/Outsourcing
  3. Sampling of System Components
  4. Multiple Acquirers
  5. P2PE Program Guide

Scope of Assessment for P2PE Solutions

The first step of a P2PE solution assessment is to accurately determine the scope of the solution. At least annually and prior to each assessment, the solution provider should confirm the accuracy of their solution scope by identifying all devices, P2PE data flows and processes, key-management functions and account-data stores, and ensure they are included in the solution scope. To ensure the accuracy of the solution scope is maintained on an on going basis, the solution provider must have processes in place that ensure the following:

  • Any changes are implemented in a manner that ensures continued adherence to P2PE requirements for the entire solution.
  • Any new rollouts/additions adhere to all P2PE solution requirements.
  • Any new rollouts/additions are included in the next P2PE assessment.

Network Segmentation

The solution provider must ensure that network segmentation is in place between any systems owned or managed by the solution provider that are used in the P2PE solution, and any that are not included in their PCI DSS compliant environment. The QSA (P2PE) must validate that the network segmentation is adequate to isolate the P2PE environment from out-of-scope networks and systems.

Third Parties/Outsourcing

A given P2PE solution may be entirely performed and managed by a single solution provider, or the solution provider may outsource certain functions (for example, loading keys into POIs) to third parties who perform these functions on behalf of the solution provider. All third parties that perform P2PE functions on behalf of the assessed P2PE solution provider, including POI vendors, KIFs, CAs, etc., must be validated per P2PE solution requirements.

There are two options for third-party entities performing functions on behalf of solution providers to validate compliance:

  1. They can undergo a P2PE assessment of relevant P2PE requirements on their own and provide evidence to their customers to demonstrate their compliance; or
  2. If they do not undergo their own P2PE assessment, they will need to have their services reviewed during the course of each of their solution provider customers’ P2PE assessments.

Multiple Acquirers

The P2PE standard outlines the technology and processes needed to ensure the security of a solution that protects account data from the point of interaction to the solution provider. In some instances, multiple acquirers or multiple solution providers may manage one or more P2PE solutions on the same merchant POI device. P2PE does not preclude these scenarios, as the business processes which govern this shared environment are outside the responsibility of the PCI SSC.

P2PE Program Guide

Please refer to the P2PE Program Guide for information about the P2PE program, including the following topics:

  • P2PE Report on Validation submission and acceptance processes
  • Annual renewal process for solutions included on the list of Validated P2PE Solutions
  • Notification responsibilities in the event a listed P2PE solution is determined to be at fault in a compromise

Third Parties/Outsourcing

A given P2PE solution may be entirely performed and managed by a single solution provider, or the solution provider may outsource certain functions (for example, loading keys into POIs) to third parties who perform these functions on behalf of the solution provider. All third parties that perform P2PE functions on behalf of the assessed P2PE solution provider, including POI vendors, KIFs, CAs, etc., must be validated per P2PE solution requirements.

There are two options for third-party entities performing functions on behalf of solution providers to validate compliance:

  1. They can undergo a P2PE assessment of relevant P2PE requirements on their own and provide evidence to their customers to demonstrate their compliance; or
  2. If they do not undergo their own P2PE assessment, they will need to have their services reviewed during the course of each of their solution provider customers’ P2PE assessments.

At-a-Glance – Steps Required to Create and Validate a P2PE Solution

The process for developing and validating a P2PE solution that uses SCDs for encryption, decryption, and cryptographic key management is provided below. This flow chart and the following table illustrate the parties responsible for implementing requirements and validating compliance with each domain, the high-level purpose of controls for each domain, and how validation of each domain can ultimately lead to a P2PE solution validation.

Like a lot of people I shall be looking into the details to see where existing and planned solutions meet the standard. The full 210 page document can be found here.

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The PCI SSC has opened its registration for the 2012 PCI Community Meetings

PCI North American Community Meeting will be held on September 12-14, 2012 in Orlando, Florida

PCI European Community Meeting will be held this year in Dublin, Ireland, October 22-24, 2012

This year’s meetings offer Council Participating Organizations and PCI stakeholders access to three days of knowledge sharing, networking and learning, including keynote presentations from industry experts, PCI case studies, and technical sessions.

“2012 is a critical year in the standards development process that hinges on feedback from the PCI community. At this year’s meeting, we’ll focus on discussing stakeholder feedback on the standards in preparation for release of the next versions of the PCI DSS and PA-DSS in 2013, as well as share our successes and challenges, ideas and suggestions as a community,” said Bob Russo, general manager, PCI Security Standards Council. “We’ll discuss Council initiatives, including the Point-to-Point Encryption (P2PE) program, mobile payment acceptance security and other technology areas, as well as the work being done through our Special Interest Groups. Attendees will also have the opportunity to take advantage of our PCI SSC Training offerings.”

New to this year’s agenda, the Community Meetings will also feature:

  • Increased networking opportunitie
  • Targeted breakout sessions for different stakeholder groups
  • More industry case studies delivered by members of the PCI community
  • Expanded opportunities to meet with card brands
  • Two-day vendor showcase
  • Event mobile app to help make the most of attendees’ time

Special sessions for Qualified Security Assessors (QSAs) and Approved Scanning Vendors (ASVs) will be held at the meetings.

Several training courses will also be available. These offerings provide participants the opportunity to combine the value of peer to peer education at the Community Meeting with more formal training sessions, maximizing their time in Orlando and Dublin.

“The record attendance at last year’s meeting is a strong testament to the work that together we as a community are doing to drive payment security forward globally, but especially within Europe,” said Jeremy King, European Regional Director. “I’m thrilled about the growing involvement of the PCI community in Europe and look forward to coming together in Dublin to continue this momentum.”

Attendance fees:

  • Participating Organization: First two registrants are free; $395 for additional registrants
  • Qualified Security Assessor (QSA)/Approved Scanning Vendor (ASV)/Internal Security Assessor (ISA)/PIN Transaction Security (PTS) members: First registrant is free; $695 for additional registrants

For more information, or to register

See you in Dublin.

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