Search

Brian Pennington

A blog about Cyber Security & Compliance

Category

PCI DSS Compliance

2018 changes to PCI DSS v3.2

Several PCI DSS requirements from version 3.2 come into effect at the end of January, 2018 (that’s just five months from now!).

Here is a list of some of the changes that will come into effect:-

3.5.1: Full documentation of all cryptographic architecture (service providers only)

6.4.6:  Change management processes that include verification of any PCI DSS impact for changes to systems or networks

8.3.x:  MFA for all non-console access to CDE.  This requirement has been the subject of much discussion, and we expect many entities to require remediation.

10.8:   Detection and reporting of all critical security control system failures (service providers only)

11.3.4.1: Penetration testing must now be performed every 6 months, as well as after any segmentation changes. (service providers only)

12.4.1: Executive management must establish PCI responsibilities and compliance program management (service providers only)

12.11.x: Quarterly personnel reviews P&P’s (service providers only)

ADVICE FROM AN ASSESSOR: DevOps, Automation, Security and Compliance

By Andrew Barratt, QSA, PCIP.  Managing Director, International/Managing Principal, Payments, Application Validation
Coalfire; Manchester, UK, http://www.coalfire.com

Phew, the title of this post alone sounds like it could be quite a lot to deal with!

So what is DevOps?  DevOps is simply the blending of infrastructure operations processes and software development to enable faster changes to business applications/technology.  These processes share a lot of ideology with the Agile & Lean camps but are more fundamentally trying to bridge the traditional divide between the development world and the IT operations/Service management teams.

In practice, DevOps can mean a lot of different things to different audiences and sometimes it can be difficult to apply compliance requirements without getting a good understanding of what DevOps is for your company.

Terms such as ‘treat your code as infrastructure’ can often scare the life out of traditional auditors along with the fear that with rapid release and change comes rapid loss of control. These shouldn’t be scary but should be embraced and understood. In audit parlance these processes can become embedded, configurable application controls that require less substantive audit testing and sampling when under scrutiny and allow the focus to be on how they are designed to be a security control.

DevOps environments typically make heavy(think obsessive!) use of automation tools to enable rapid change and release processes to be possible at large and frequent scale. This is typically where the confusion starts to begin when evaluating these environments for security and compliance purposes. Typical service management controls such as change management on the surface may appear to have been cast aside in the rush to ‘be DevOps’. This rush to implement tooling can often lead to the underlying processes being weak or ill conceived. However this is common in other disciplines too. Poor planning = poor performance.

DevOps done well can bring a great set of tools and capability for building secure, scalable and compliant environments. Building on modern source control, streamlining change control and building dependency on the tools authentication and access control can quickly be used to demonstrate the control requirements of many compliance frameworks including the PCI DSS. Just doing things faster or without lots of paper forms and signatures on doesn’t necessarily equate to non-compliance.

The implementation of PCI DSS requirements 2 and 6 can be rapidly transformed using a DevOps approach. If we look at requirement 2 as being primarily focused on hardened configuration management traditionally seen as an ‘Ops’ area, whilst Requirement 6 focuses on change management and software development.

There is nothing fundamentally in these requirements (or in other areas of the DSS) that prevents a DevOps environment being used to support and implement PCI compliance if done carefully. Whilst the security and compliance mandate might tweak certain implementation decisions most of the tools marketed for ‘DevOps’ support building workflows that can be used for approval / review decisions and capture/log the necessary approval processes to support compliance. As the level of automation increases so can the ease of which compliance requirements be met.

Recently I worked with a client that had invested heavily in building their dev-ops tooling but had built in PCI requirements as part of this process so also incorporated automation of documentation production too.  Their focus was, and still is, to automate as much as possible into the release process to minimize the failure of an activity. Every time a new release was pushed all configuration documentation was also updated automatically (supporting requirement 2) .

This particular client used a software issue and tracking tool that could be used to demonstrate management approval for changes as well as to show that code review processes had been followed. As they continued to improve they were investigating automation of their code review processes so that static analysis tools were orchestrated immediately after changes were approved as part of the build process.

One of the biggest challenges they faced initially was the size of their team, they were small and specialist and in the past had struggled with creating segregation of duties between their test/production systems.  Moving to DevOps helped with this significantly. No developers were required to have access to production systems in any manner as the build and release process was entirely orchestrated by tools with an approval workflow that the developers couldn’t authorize alone. The tools were the only thing with the ability to push to their production systems and the workflow done under management approval. These tools were treated the same way as other in-scope systems but the overhead from this was so minimal that it enabled them meet security requirements without complicated manual processes and multiple sets of access permissions.

PCI SSC revises date for migrating off vulnerable SSL and early TLS encryption

Following significant feedback from the global PCI community and security experts, the Payment Card Industry Security Standards Council (PCI SSC) has announced a change to the date that organizations who process payments must migrate to TLS 1.1 encryption or higher.

The original deadline date for migration, June 2016, was included in the most recent version of the PCI Data Security Standard, version 3.1 (PCI DSS 3.1), which was published in April of 2015. The new deadline date, June 2018, will be included in the next version of the PCI Data Security Standard, which is expected in 2016.

Early market feedback told us migration to more secure encryption would be technically simple, and it was, but in the field a lot of business issues surfaced as we continued dialog with merchants, payment processors and banks,” said Stephen Orfei, General Manager, PCI SSC. “We want merchants protected against data theft but not at the expense of turning away business, so we changed the date. The global payments ecosystem is complex, especially when you think about how much more business is done today on mobile devices around the world. If you put mobile requirements together with encryption, the SHA-1 browser upgrade and EMV in the US, that’s a lot to handle. And it means it will take some time to get everyone up to speed. We’re working very hard with representatives from every part of the ecosystem to make sure it happens as before the bad guys break in.

Some payment security organizations service thousands of international customers all of whom use different SSL and TLS configurations,” said Troy Leach, Chief Technology Officer, PCI SSC. “The migration date will be changed in the updated Standard next year to accommodate those companies and their clients. Other related provisions will also change to ensure all new customers are outfitted with the most secure encryption into the future. Still, we encourage all organizations to migrate as soon as possible and remain vigilant. Staying current with software patches remains an important piece of the security puzzle

In addition to the migration deadline date-change, the PCI Security Standards Council has updated:

  • A new requirement date for payment service providers to begin offering more secure TLS 1.1 or higher encryption
  • A requirement for new implementations to be based on TLS 1.1 or higher
  • An exception to the deadline date for Payment Terminals, known as “POI” or Points of Interaction.

Merchants are encouraged to contact their payment processors and / or acquiring banks for detailed guidance on upgrading their ecommerce sites to the more secure encryption offered by TLS 1.1 or higher.

PCI Security Standards council announces 2016 special interest group election results

The Payment Card Industry Security Standards Council (PCI SSC), has announced the election results for its 2016 Special Interest Group (SIG) project. 

Special Interest Groups are community-led initiatives that address important security challenges related to PCI Security Standards. One new Special Interest Group is selected every year, but groups may run for more than 12 months in order to complete the agreed-upon goals. 

PCI member organizations, including merchants, financial institutions, service providers and associations, voted on five proposed Special Interest Group topics submitted by their peers. The winning topic selected for 2016 was, “Best Practices for Safe E-Commerce 

The new Special Interest Group is slated to kick off in January 2016

The Council invites PCI member organizations and assessors interested in getting involved in this SIG project to register on the PCI SSC website by 4 January 2016.  

The community choose from among five strong proposals, so it was certainly not an easy decision,” said Jeremy King, International Director, PCI SSC. “We are encouraged by how many Participating Organizations were involved in the submission and election process this year. SIGs continue to be an excellent vehicle for putting their expertise to work to improve payment card security globally

 

500 European Business Leaders attend the PCI Security Standards Council Community Meeting

This week business leaders and security professionals gathered in Nice, France to discuss payment based security and especially PCI DSS and P2Pe. 

Jeremy King PCI Security Standards Council International Director said, The new European Commission Payment Services Directive 2 along with the European Banking Authority Guidelines for Securing Internet Payments have clear and detailed requirements for organisations in protecting cardholder data. Add to that the soon to be released General Data Protection Regulation which covers all data security, and you have a massive increase in data security, which when implemented will impact all organisations in Europe and beyond, 

These regulations will force organisations to take security seriously, and PCI provides the most complete set of data security standards available globally. Establishing good data security takes time and effort. Organisations need to know these regulations are coming and put a plan in place now for ongoing security

With 70% of all card fraud coming from Card-Not-Present (CNP), a figure that surpasses the previous 2008 record which was set during the EMV chip migration, it is a critical time for the industry. 

A significant amount of the conference was spent on new and developing technologies including::

  • Cloud – Daniel Fritsche of Coalfire presented on Virtualisation and the Cloud
  • Mobile – several presentations including the Smart Payments Association
  • Point to Point Encryption (P2PE) – Andrew Barratt of Coalfire delivered a panel discussion
  • Tokenisation – A presentation by Lufthansa Systems 

Jeremy King added. PCI is committed to helping organisations globally improve their data security. Our range of standards, and especially our supporting documents, are designed to help all companies improve and protect their data security. The annual Community Meeting is a big part of our efforts to engage with companies from all sectors, sharing and exchanging information to ensure they have the very best level of security 

We must work together to tackle card-not-present fraud with technologies such as point-to-point encryption and tokenisation that devalue data and make it useless if stolen by criminals.

Attendees included experts from Accor Hotels, , British Telecommunications, Capita, Coalfire Systems Limited, Accor Hotels, Lufthansa, Virgin Trains, Vodat International and hundreds of others.

Payment Card Industry issues new guidance to help organizations respond to data breaches

For any organization connected to the internet, it is not a question of if but when their business will be under attack, according to a recent cybersecurity report from Symantec, which found Canada ranked No. 4 worldwide in terms of ransomware and social media attacks last year. These increasing attacks put customer information, and especially payment data at risk for compromise.

When breaches do occur, response time continues to be a challenge. In more than one quarter of all breaches investigated worldwide in 2014 by Verizon, it took victim organization weeks, or even months, to contain the breaches. It is against this backdrop that global cybersecurity, payment technology and data forensics experts are gathering in Vancouver for the annual PCI North America Community Meeting to address the ongoing challenge of protecting consumer payment information from criminals, and new best practices on how organizations can best prepare for responding to a data breach. 

A data breach now costs organizations an average total of $3.8 million. However, research shows that having an incident response team in place can create significant savings. Developed in collaboration with the Payment Card Industry (PCI) Forensic Investigators (PFI) community, Responding to a Data Breach: A How-to Guide for Incident Management provides merchants and service providers with key recommendations for being prepared to react quickly if a breach is suspected, and specifically what to do contain damage, and facilitate an effective investigation. 

The silver lining to high profile breaches that have occurred is that there is a new sense of urgency that is translating into security vigilance from the top down, forcing businesses to prioritize and make data security business-as-usual,” said PCI SSC General Manager Stephen W. Orfei. “Prevention, detection and response are always going to be the three legs of data protection. Better detection will certainly improve response time and the ability to mitigate attacks, but managing the impact and damage of compromise comes down to preparation, having a plan in place and the right investments in technology, training and partnerships to support it

This guidance is especially important given that in over 95% of breaches it is an external party that informs the compromised organization of the breach,” added PCI SSC International Director Jeremy King. “Knowing what to do, who to contact and how to manage the early stages of the breach is critical

At its annual North America Community Meeting in Vancouver this week, the PCI Security Standards Council will discuss these best practices in the context of today’s threat and breach landscape, along with other standards and resources the industry is developing to help businesses protect their customer payment data. Keynote speaker cybersecurity blogger Brian Krebs will provide insights into the latest attacks and breaches, while PCI Forensic Investigators and authors of the Verizon Data Breach Investigation Report and PCI Compliance Report, will present key findings from their work with breached entities globally. Canadian organizations including City of Calgary, Interac and Rogers will share regional perspectives on implementing payment security technologies and best practices. 

Download a copy of Responding to a Data Breach: A How-to Guide for Incident Management here 

The original PCI SSC press release can be found here.

Mobile Payments Data Breaches will Grow

An ISACA survey of more than 900 cybersecurity experts shows that

  • 87% expect to see an increase in mobile payment data breaches over the next 12 months
  • 42% of respondents have used this payment method in 2015

The 2015 Mobile Payment Security Study from global cybersecurity association ISACA suggests that people who use mobile payments are unlikely to be deterred by security concerns.

Other data from the survey show that cybersecurity professionals are willing to balance benefits with perceived security risks of mobile payments:

  • 23% believe that mobile payments are secure in keeping personal information safe.
  • 47% say mobile payments are not secure and 30% are unsure.
  • At 89%, cash was deemed the most secure payment method, but only 9% prefer to use it.

Mobile payments represent the latest frontier for the ongoing choice we all make to balance security and privacy risk and convenience,” said John Pironti, CISA, CISM, CGEIT, CRISC, risk advisor with ISACA and president of IP Architects. “ISACA members, who are some of the most cyber-aware professionals in the world, are using mobile payments while simultaneously identifying and contemplating their potential security risks. This shows that fear of identity theft or a data breach is not slowing down adoption and it shouldn’t as long as risk is properly managed and effective and appropriate security features are in place

Reports say that contactless in-store payment will continue to grow. Overall, the global mobile payment transaction market, including solutions offered by Apple Pay, Google Wallet, PayPal and Venmo, will be worth an estimated US $2.8 trillion by 2020, according to Future Market Insights.

ISACA survey respondents ranked the major vulnerabilities associated with mobile payments:

  1. Use of public WiFi (26%)
  2. Lost or stolen devices (21%)
  3. Phishing/shmishing (phishing attacks via text messages) (18%
  4. Weak passwords (13%)
  5. User error (7%)
  6. There are no security vulnerabilities (0.3%)

What Consumers Need to Know

According to those surveyed, currently the most effective way to make mobile payments more secure is using two ways to authenticate their identity (66%), followed by requiring a short-term authentication code (18%). Far less popular was an option that puts the onus on the consumer installing phone-based security apps (9%).

CSX-Mobile-3-lg

People using mobile payments need to educate themselves so they are making informed choices. You need to know your options, choose an acceptable level of risk, and put a value on your personal information,” said Christos Dimitriadis, Ph.D., CISA, CISM, CRISC, international president of ISACA and group director of information security for INTRALOT. “The best tactic is awareness. Embrace and educate about new services and technologies

Understand your level of risk: Ask yourself what level of personal information and financial loss is acceptable to balance the convenience of mobile payments.

Know your options: Understand the security options available to manage your risk to an acceptable level. Using a unique passcode should be mandatory, but also look into encryption, temporary codes that expire and using multiple ways to authenticate your identity.

Value your personal information: Be aware of what information you are sharing e.g., name, birthday, national identification number, pet name, email, phone number. These pieces of information can be used by hackers to gain access to accounts. Only provide the least amount of information necessary for each transaction.

Security Governance for Retailers and Payment Providers

In the emerging mobile payment landscape, ISACA notes that there is no generally accepted understanding of which entity is responsible for keeping mobile payments secure—the consumer, the payment provider or the retailer. One approach is for businesses to use the COBIT governance framework to involve all key stakeholders in deciding on an acceptable balance of fraud rate vs. revenue. Based on that outcome, organizations should set policies and make sure that mobile payment systems adhere to them.

Members of the IT or information security group taking part in the discussion should also ensure they are keeping up to date with the latest cybersecurity developments and credentials. A joint 2015 ISACA/RSA study shows that nearly 70% of information security/information technology professionals require certification when looking for candidates to fill open security positions.

The full ISACA Press Release can be found here.

Guest blog: PCI audits and how to recognize a good QSA auditor and partner

Many organizations approach a PCI audit with fear and trepidation. There are a lot of stories out there about how difficult, expensive and disruptive a PCI audit can be, but I want to see if I can add some balance to this view. I believe that when it comes to a PCI auditor it matters a great deal who you are working with. We just completed a PCI audit of our Alliance Key Manager for VMware solution and it gave me a whole new perspective and attitude about the audit process. Our PCI work was conducted by Coalfire, a security company that provides PCI audit services as well as audit services for the health and financial communities. Most of my remarks will reflect on the great experience we had with Coalfire and some of the lessons we learned.

As is true of financial auditors, the QSA auditor has a duty to accurately assess the security of your IT systems to insure that they meet or exceed the PCI Data Security Standards (PCI DSS) as outlined by the PCI Security Standards Council (PCI SSC). They have a professional responsibility to tell you where you meet the PCI DSS standard, and where you fall short. That “falling short” part is the thing most people dread hearing about.

I would suggest that this is exactly where a good security audit can be very helpful. We need to know where our security is weak, and we need to know how to fix the problems. A good QSA auditor will be more than a gatekeeper for the PCI security standards – they will be a trusted advisor on how to get things right from a security perspective. That practical advice is exactly what we need to protect our sensitive data.

Finding problems and fixing them is less expensive than suffering a data breach and then scrambling to fix the problems.

Another often overlooked benefit of having a good QSA auditor is that you get a get a trusted advisor in the process. It is one thing to have an auditor point out the faults in your security strategy, it is another to find an auditor who can advise you on the security strategies and potential solutions that can help you. While there must be an arms-length relationship between an auditor and a solution provider, your QSA auditor should be able to point you to a number of solutions that can help you mitigate security weaknesses. An experienced auditor is going to help you navigate towards a good solution.

It is hard to quantify the benefit of this type of guidance, but I personally think it is invaluable.

The take-away is that you should set high expectations for the relationship you develop with your QSA auditor. You can walk away from the experience with checks in boxes, or you can meet PCI compliance AND achieve a credible security strategy and trusted advisor. I found the latter in my relationship with Coalfire.

Patrick Townsend

Townsend Security

Congratulations to the new board members of the PCI Standards Council

The new members to the board are from:-

  • Amazon.com
  • Barclaycard
  • British Airways PLC
  • Carlson Wagonlit Travel
  • Cartes Bancaires
  • Chase Paymentech Solutions
  • Cielo S.A.
  • Cisco
  • Citigroup Inc.
  • Elavon Merchant Services
  • European Payment Council AISBL
  • European Payment Service Providers for Merchants (EPSM)
  • First Bank of Nigeria
  • Global Payments Direct Inc.
  • HP
  • Ingenico
  • Middle East Payment Services (MEPS)
  • PayPal Inc
  • Retail Solutions Providers Assn. (RSPA)
  • RSA
  • Square, Inc.
  • Starbucks
  • VeriFone Inc
  • Wal-Mart Stores Inc
  • Wells Fargo
  • WorldPay

Among many duties, Board of Advisor members provide directional and technical input on matters of focus vital for maintaining the security standards that protect digital purchasing and payments. Areas of importance include new cybercrime tactics, public-private-law enforcement information sharing, app development and merchant needs in developing economies. New board members are already contributing to the PCI security community through other volunteer opportunities as Participating Organizations. The PCI Council welcomes any person or organization to join in the fight against cybercrime by volunteering as a Participating Organization.

PCI SSC General Manager Stephen W. Orfei said

Cybercrime is standing in the way of economic growth for all businesses, including start-ups in the developing world and multinationals. Criminal networks are well funded and highly motivated to steal our hard-earned money and our personal information. At the Council we are grateful to have some of the best economic and security minds in the world joining the board to help tackle the challenge that cybercriminals present

PCI SSC International Director Jeremy King, said

The simple act of accepting a single credit card payment, an online payment or a mobile payment can send money and data bouncing around the world to dozens of places. And on every device, computer and network there are new methods thieves are creating to steal from us. Fighting a threat like that takes the cooperation of all 700 PCI Participating Organizations. PCI is fortunate to have new board members from Europe, the Middle East, Africa and Latin America charting the path for payment security. Past board members from around the world have been a massive help to the community, helping us keep ahead of new risks. We look forward to working with the new board in the same capacity

Create a free website or blog at WordPress.com.

Up ↑

%d bloggers like this: