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Brian Pennington

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P2PE

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.

The hospitality industry increases it’s adoption of Tokenization and P2Pe

The 2014 and 16th edition of the Hospitality Technology magazine Restaurant Technology Study has produced an 18 page report. 

Of specific interest to me was Chapter 5 Payment Security – “End of Swipe-and-Sign Looms”, the chapter states:-

The U.S. payment industry is in a period of transition. October 2015 will mark the end of swipe-and-sign. While card brands are committed to swapping mag-strip for EMV chip-based cards, the standard for authentication remains under debate: signature capture or PIN. While PIN authentication is considered the more secure option, there’s concern that Americans, who tend to have a variety of credit cards, would struggle to manage multiple PINs.

As the restaurant industry, and U.S. merchants at large, take a wait-and-see approach, HT (Hospitality Technology) measures the industry’s current and planned payment security practices in its 2014 Restaurant Technology Study.

The food service industry, with its fragmented technology, has historically been a target for card data theft. The sunset for swipe cards will be a welcome improvement. EMV preparedness is on restaurants’ radar, with 70% of those surveyed agreeing that it is important to have a well-defined roadmap for EMV preparedness.

When asked about their organization’s current approach to preparing for EMV

  • 26% report having some form of road-map in place; likely due to the lack of a standard
  • 37% will make this a priority in the year ahead.

What’s more, confusion with the current PCI DSS remains:-

  • 86% reporting that their organizations are “in compliance” but far fewer are able to identify compliance with some of the 12 specific requirements
  • 72% report that their organization maintains a policy that addresses information security for employees and contractors (item 12 of the PCI DSS).

With payment security an on going process and a moving target, restaurants are leveraging third parties for assistance. More than half of those surveyed outsource their PCI compliance efforts (54%), and nearly as many (52%) have purchased some form of breach protection or insurance.

Respondents were further asked about their organizations’ use of tokenization and point-to-point encryption (P2PE). Though not a requirement of PCI DSS, these technologies can reduce scope by shrinking the footprint where cardholder data is located throughout the organization.

  • 43% use P2PE and 33% plan to add the technology by 2016
  • 36% use Tokenization and an additional 30% have future implementation plans

The full report can be found here..    

Retail and Financial Sectors Overly Confident About Breach Detection

Atomic Research have announced the results of a survey sponsored by Tripwire of 102 financial organizations and 151 retail organizations in the U.K., all of which process card payments.

The survey results indicate that recent data breaches have had little impact on the security controls of retail and financial organisations.

35% said it would take as long as two to three days to detect a breach on their systems

However, according to the 2014 Verizon Data Breach Investigations Report, 85% of point-of-sale intrusions took weeks to discover and 43% of web application attacks took months to discover.

It is shocking to see the high level of confidence exhibited by respondents in the wake of the recent series of high-profile cardholder data breaches,” said Tim Erlin, director of IT security and risk strategy for Tripwire, in response to the findings. “6% of respondents said they are confident that their security controls are able to prevent the loss of data files, but this confidence flies in the face of recent evidence to the contrary

The Payment Card Industry Data Security Standard is a security standard that outlines minimum security requirements for organizations that handle cardholder information. When asked how important PCI compliance is to their overall security program, 43% of respondents said it was the backbone of their security program, and 36% said it was half of their security program. However, in order to protect confidential customer data, organisations must apply additional security controls.

Other findings include:

  • 24% of those studied have already suffered a data breach where Personally Identifiable Information (PII) was stolen or accessed by intruders
  • 36% of respondents do not have confidence in their incident response plan
  • 51% of respondents are only somewhat confident that their security controls can detect malicious applications
  • 40% of respondents said they do not believe that recent high profile cardholder breaches have changed the level of attention executives give to security

It is great that recent breaches have increased cybersecurity awareness and internal dialogue. However, the improved internal communication may be biased by a false sense of security,” said Dwayne Melancon, chief technology officer for Tripwire. “For example, 95% of respondents said they would be able to detect a breach on critical systems within a week. In reality, nearly all of the recent publicly disclosed breaches have gone on for months without detection

Furthermore, only 60% of respondents believe their systems have been hardened enough to prevent the kind of data loss similar to that seen in recent high profile breaches,” Melancon continued. “These attitudes seem to indicate a high degree of overconfidence or naiveté among information security practitioners. I believe a number of these organizations may be in for a rude awakening if their systems are targeted by criminals

The Tripwire report can be found here.

P2Pe, Pseudo-P2Pe, End-2-End Encryption, Linked Encryption, they are all good

This week’s Vendorcom Secure Payments Special Interest Group (SIG) met to discuss P2Pe and it became clear that there are many ways to achieve a compliant outcome.

My first impression was the large number of attendees at the SIG, 50+, only one of them was a Merchant. The rest were a mixed bag of Acquirers, PSPs, QSAs, Vendors and Consultants making it more of a Vested Interest Group than a Special one.

The Logic Group (TLG) started the presentations and covered their listed P2Pe solutions and how they achieved compliance. They explained all the hard work getting all the elements through the audits and the 970 P2Pe Controls (more than double that of PCI DSS).

TLG cited the issues of key custody and management and how once during the development period it required 6 people to cover the physical as well as the logical security requirements.

The Q&A session before lunch was mostly aimed at John Elliot of VISA Europe who handled even the most difficult questions very well and delivered the answers with humour. He even confirmed that next week there is a gathering in the US to ratify the much discussed Tokenization standard and some clarifications to the PCI DSS version 3.0. He however was wrong on one prediction that the new Self Assessment Questionnaires (SAQ) would be out on Thursday and they weren’t but to be fair to John almost everyone associated with PCI has tried to predict the arrival of the new SAQs and got it wrong. They finally came out today (28th February 2014).

After lunch Spire Payments and MagTek presented on their device solutions and their compatibility with the PCI PTS SRED and how they could fit into a P2Pe compliant solution.

Next up were Vodat International with their alternative to P2Pe. The Vodat solution is a managed end to end solution with encryption and resilience. Ian Martin’s presentation was supported by VISA Europe as a way to achieve PCI DSS compliance.

Some other discussion point

  • Linked Encryption combined with EMV could make a significant security improvement for the US market
  • Some merchants think switching to Ingenico gives them P2Pe
  • Some merchants and the PCI SSC are concerned that there are only two listed P2Pe solutions
  • PCI SSC would like to make P2Pe modular e.g. if you want to do your own key management or choose your own PEDs, etc.
  • An April deadline for moving to TLS 1.1 or above is not true, maintaining secure software is always required.
  • All mobile payments are mandated to have P2Pe
  • P2Pe will probably never be mandatory, except for mobile
  • If you have a certified P2Pe solution you can complete an SAQ no matter what size of merchant you are

It was an interesting day and after all the presentations and discussions what became clear is there are many ways to achieve PCI DSS compliance; Point to Point Encryption (P2Pe), Pseudo-P2Pe, End-2-End Encryption and Linked Encryption or a combination of them.

What is not in doubt is the chosen solutions must meet the business profile of the merchant and help them achieve PCI DSS compliance. The solution itself will not achieve compliance because there is more to compliance than installing a solution for example there is the on going maintenance of compliance and the human element.

Whichever solution you represent or are looking to buy lets hope it is installed and maintained well enough to meet and maintain continuous security and PCI DSS compliance.

PCI Security Standards Council releases Point-to-Point encryption (P2PE) resources

The PCI Security Standards Council (PCI SSC), has announced availability of the Point-to-Point Encryption (P2PE) Program Guide and Self-Assessment Questionnaire (SAQ) to support implementation of hardware-based point-to-point encryption (P2PE) solutions. They are downloadable from the PCI SSC website in an MS Word format.

The resources follow the Council’s release of updated Solution Requirements and Testing Procedures for hardware-based P2PE solutions in April, (find the link in my resources page)which provide a method for vendors to validate their P2PE solutions and for merchants to reduce the scope of their PCI DSS assessments by using a validated P2PE solution for accepting and processing payment card data.

Eligible merchants using these P2PE hardware solutions may be able to reduce the scope of their PCI DSS assessments and validate to a reduced set of PCI DSS requirements. To help with this validation process, the Council has developed a new Self-Assessment Questionnaire (SAQ P2PE-HW).

SAQ P2PE-HW is for merchants who process cardholder data via hardware terminals included in a validated P2PE solution and consists of the following components:

  • Merchant eligibility criteria
  • SAQ completion steps
  • Self-Assessment Questionnaire (validation of PCI DSS Requirements)
  • Attestation of Compliance, including Attestation of PIM Implementation

Merchants should refer to their acquirer and/or payment brand to determine if they are eligible to use this new SAQ.

The Council has also updated the PCI DSS SAQ Instructions and Guidelines document to provide additional guidance on use of the SAQ P2PE-HW.

The PCI P2PE Program Guide is designed to help solution providers, application vendors, and P2PE assessors understand how to complete a P2PE assessment and submit it to the Council for acceptance and listing on the PCI SSC website.

The document includes:

  • Overview of P2PE solution validation processes
  • Considerations for P2PE Solution providers preparing for assessment
  • Reporting considerations for P2PE assessors
  • Considerations for managing validated P2PE Solutions
  • Listing of applications used in P2PE solutions

Solution providers, application vendors, and P2PE assessors can use this document immediately to plan for their P2PE assessments.

The Council will shortly be providing templates and Reporting Instructions for P2PE validation reports, as well as new Attestations of Validation (AOVs) and vendor release agreement (VRA).

P2PE assessors, solution providers and application vendors can then complete their assessments of P2PE Solutions and applications and submit their reports and validation documentation to the Council for acceptance and listing. The Council will list the validated solutions on the PCI SSC website for merchants to use.

“These resources are a critical part of rolling out this program,”

said Bob Russo, general manager, PCI Security Standards Council

“The program guide outlines the submission and listing process for P2PE solution providers and application vendors who want to validate their products, while the SAQ will help simplify PCI DSS validation efforts for merchants taking advantage of this process to minimize the amount of cardholder data in their environments.”

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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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