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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.

100 Percent of Retailers Disclose Cyber Risks

According to BDO’s analysis of risk factors listed in the most recent 10-K filings of the 100 largest U.S. retailers, risk associated with a possible security breach was cited unanimously by retailers, claiming the top spot, up from the 18th spot in 2007.

Since major retail security breaches began making national headlines in 2013, retailers have become acutely aware of the growing cyber threat and cyber-related risks. Between new point-of-sale systems and evolving digital channels, the industry faces unique vulnerabilities: Retailers are responsible for safeguarding consumer data as well as their own, in addition to protecting against potential gaps in security related to third-party suppliers and vendors.

2016 marks the 10th anniversary of our retail risk factor analysis, and throughout the decade, we’ve seen the retail landscape undergo a dramatic evolution in response to the recession, new and maturing e-commerce channels and evolving consumer preferences,” said Doug Hart, partner in BDO’s Consumer Business practice. “Retailers over the years have proven to be in tune with the industry-wide issues and trends that could pose risks to their businesses, and they are clearly not tone deaf when it comes to reacting to the urgency of cybersecurity

The following chart ranks the top 25 risk factors cited by the 100 largest U.S. retailers:

Top 20 Risks for Retailers 2016 2015 2014
General Economic Conditions #1 100% #1 100% #1 100%
Privacy Concerns Related to Security Breach #1t 100% #4t 99% #8 91%
Competition and Consolidation in Retail Sector #3 98% #1t 100% #3 98%
Federal, State and/or Local Regulations #4 96% #1t 100% #2 99%
Natural Disasters, Terrorism and Geo-Political Events #5 94% #7 96% #13 87%
Implementation and Maintenance of IT Systems #6 93% #4 99% #7 92%
U.S. and Foreign Supplier/Vendor Concerns #6t 93% #6 98% #4 96%
Legal Proceedings #6t 93% #9t 95% #8t 91%
Labor (health coverage, union concerns, staffing) #9 91% #7t 96% #5 94%
Impediments to Further U.S. Expansion and Growth #10 90% #12t 92% #17 78%
Dependency on Consumer Trends #11 88% #9 95% #6 93%
Consumer Confidence and Spending #12 87% #15 89% #8t 91%
Credit Markets/Availability of Financing and Company Indebtedness #13 85% #11 94% #11 89%
Failure to Properly Execute Business Strategy #14 82% #12 92% #11t 89%
Changes to Accounting Standards and Regulations #15 76% #14 90% #13t 87%
International Operations #16 73% #17 86% #15 80%
Loss of Key Management/New Management #16t 73% #19 80% #16 79%
Marketing, Advertising, Promotions and Public Relations #18 66% #25 68% #24 64%
Consumer Credit and/or Debt Levels #19 62% #27 65% #23 65%
Joint Ventures #20 61% #21 76% #18 74%

Additional findings from the 2016 BDO Retail Risk Factor Report:

Cyber Risks Include Compliance Measures

As the cyber threat looms larger, retailers are bracing for new and emerging cybersecurity and data privacy legislation. Risks associated with cyber and privacy regulations were cited by 76 percent of retailers this year. This is in line with the findings from the 2016 BDO Retail Compass Survey of CFOs, in which nearly 7 in 10 retail CFOs said they expected cyber regulation to grow in 2016. These concerns have been highlighted by President Obama’s recently unveiled Commission on Enhancing National Cybersecurity and continued debate in Congress over information sharing between the government and private industry.

Retailers have not escaped regulatory scrutiny. The industry is also subject to Europay, Mastercard and Visa (EMV) standards that bolster credit card authentication and authorization. Industry analysts estimate that just 40 percent of retailers are compliant with EMV standards despite the Oct. 1, 2015 deadline.

“Mandating EMV chip-compliant payment systems is an important first step in shoring up the industry’s cyber defenses, but it’s just the tip of the iceberg,” said Shahryar Shaghaghi, National Leader of the Technology Advisory Services practice group and Head of International BDO Cybersecurity. “Online and mobile transactions remain vulnerable to credit card fraud and identity theft, and POS systems can still be hacked and provide an access point to retailers’ networks. New forms of malware can also compromise retailers’ IT infrastructure and disrupt business operations. Every retailer will experience a data breach at some juncture; the real question is what mechanisms have been put in place to mitigate the impact.”

E-Commerce Ubiquity Drives Brick & Mortar Concerns

Impediments to e-commerce initiatives also increased in ranking, noted by 57 percent of retailers in 2016, a significant contrast from 12 percent in 2007. In 2015, e-commerce accounted for 7.3 percent of total retail sales and is continuing to gain market share.

As e-commerce grows and businesses strive to meet consumers’ demand for seamless online and mobile experiences, retailers are feeling the effects in their physical locations. The recent wave of Chapter 11 bankruptcies and mass store closings among high-visibility retailers has raised concerns across the industry. Ninety percent of retailers are worried about impediments to growth and U.S. expansion this year. Meanwhile, risks associated with owning and leasing real estate jumped 14 percentage points to 54 percent this year.

Heightened worries over the impact of e-commerce on physical locations are far reaching, driving concerns over market competition for prime real estate and mall traffic to rise 19 percentage points to 46 percent. Meanwhile, consumer demand for fast shipping fueled an uptick in risks around the increased cost of mail, paper and printing, rising 10 percentage points from seven percent in 2015 to 17 percent this year.

General Economic Conditions Hold Weight

General economic risks have been consistently top of mind for retailers throughout all ten years of this survey. Even at its lowest percentage in 2008, this risk was still the second most cited, noted by 83 percent of companies.

Despite the fact that since 2013, general economic conditions have remained tied for the top risk, concerns about specific market indicators have receded.

For more information on the 2016 BDO Retail RiskFactor Report, view the full report here.

About the Consumer Business Practice at BDO USA, LLP

BDO has been a valued business advisor to consumer business companies for over 100 years. The firm works with a wide variety of retail and consumer business clients, ranging from multinational Fortune 500 corporations to more entrepreneurial businesses, on myriad accounting, tax and other financial issues.

The State of Cybersecurity in Healthcare Organizations in 2016

ESET and the Ponemon Institute have announced results of The State of Cybersecurity in Healthcare Organizations in 2016.

According to the study, healthcare organizations average about one cyber attack per month with 48% of respondents said their organizations have experienced an incident involving the loss or exposure of patient information during the last 12 months. Yet despite these incidents, only half indicated their organization has an incident response plan in place.

The concurrence of technology advances and delays in technology updates creates a perfect storm for healthcare IT security,” said Stephen Cobb, senior security researcher at ESET. “The healthcare sector needs to organize incident response processes at the same level as cyber criminals to properly protect health data relative to current and future threat levels. A good start would be for all organizations to put incident response processes in place, including comprehensive backup and disaster recovery mechanisms. Beyond that, there is clearly a need for effective DDoS and malware protection, strong authentication, encryption and patch management

Key findings of the survey:

78% of respondents, the most common security incident is the exploitation of existing software vulnerabilities greater than three months old.

63% said the primary consequences of APTs and zero-day attacks were IT downtime

46% of respondents experienced an inability to provide services which create serious risks for patient treatment.

Hackers are most interested in stealing patient information

  • The most attractive and lucrative target for unauthorized access and abuse can be found in patients’ medical records, according to 81% of respondents.

Healthcare organizations worry most about system failures

  • 79% of respondents said that system failures are one of the top three threats facing their organizations
  • 77% cyber attackers
  • 77% unsecure medical devices

Technology poses a greater risk to patient information than employee negligence

  • 52% of respondents said legacy systems and new technologies to support cloud and mobile implementations, big data and the Internet of Things increase security vulnerabilities for patient information
  • 46% of respondents also expressed concern about the impact of employee negligence
  • 45% cited the ineffectiveness of HIPAA mandated business associate agreements designed to ensure patient information security

DDoS attacks have cost organizations on average $1.32 million in the past 12 months

  • 37% of respondents say their organization experienced a DDoS attack that caused a disruption to operations and/or system downtime about every four months. These attacks cost an average of $1.32 million each, including lost productivity, reputation loss and brand damage.

Healthcare organizations need a healthy dose of investment in technologies

  • On average, healthcare organizations represented in this research spend $23 million annually on IT
  • 12% on average is allocated to information security
  • Since an average of $1.3 million is spent annually for DDoS attacks alone, a business case can be made to increase technology investments to reduce the frequency of successful attacks

Based on our field research, healthcare organizations are struggling to deal with a variety of threats, but they are pessimistic about their ability to mitigate risks, vulnerabilities and attacks,” said Larry Ponemon, chairman and founder of The Ponemon Institute. “As evidenced by the headline-grabbing data breaches over the past few years at large insurers and healthcare systems, hackers are finding the most lucrative information in patient medical records. As a result, there is more pressure than ever for healthcare organizations to refine their cybersecurity strategies

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.

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