[Our good friend Joe Tinucci also attended the Community Meeting and shares with us his impressions of this year's program. –gaw]
I also was privileged to attend the PCI SSC Community Meeting in Vancouver. As with last year's meeting there were several trends that were apparent, both explicitly stated in the sessions and, equally important, discussed at the networking events and on the trade show floor. Here is a summary of the major trends that I heard at the meeting:
Risk, Risk, Risk
The entire first day of the meeting was devoted to updates from the Council, virtually all of them focusing on risk and risk management. This theme has carried over from last year, and I assume that it will carry forward to future years. Using a risk management-based approach it becomes easier for merchants to prioritize what to do first and where to concentrate their scarce resources. It also makes it easier to incorporate risk avoidance into ordinary business practices.
One major risk that came up repeatedly was third party service providers. It was noted that approximately 1/3 of retail breaches were due to third party vulnerabilities. Remote access by vendors to merchant systems is particularly problematic; there are standard practices that should be in place to prevent vendors from accessing merchant systems any more often than is strictly necessary.
One excellent resource for managing third parties was the Responsibility Matrix found in the Council's Third-Party Assurance Information Supplement (https://www.pcisecuritystandards.org/documents/PCI_DSS_V3.0_Third_Party_Security_Assurance.pdf). Not only does this document provide a framework for assessing the risks of third parties, but also a framework for negotiating the legal responsibilities of each party. I highly recommend that you download and use this document to help provide the structure for your third party management program.
Another theme was collaboration. I think it indicates an interest on the part of the Council to expand their purview so as to bring in additional revenues and resources, and to also work with other associations, interest groups, governmental agencies, and rule-making bodies to cooperatively secure payments. Sharing of information, whether officially sanctioned through ISACs or other mechanisms, is one of the few ways that the good guys can stay current with what the bad guys are doing.
There was a lot of discussion of incident response. The Council recently issued a supplemental guide, Responding to a Data Breach (https://www.pcisecuritystandards.org/documents/PCI_SSC_PFI_Guidance.pdf) that can serve as a checklist or guide to building your incident response program. The guide's theme of "Preparing for the Worst is the Best Defense" was repeated in multiple presentations. Prepare now to see more requirements surrounding this area in future versions of the standard. And, if you haven't yet done so, you should consider holding a "tabletop" incident response exercise just to make sure that you have identified the key players that need to be part of your IR team and that they play well together.
Another recurring theme was segmentation – of your cardholder data environment, of course, but also as applied to other environments. Segmentation is a major scope-reduction tool for PCI DSS compliance. The newest version of the DSS has an increased emphasis on this topic, particularly validation that your segmentation is working as intended – both from inside and outside the network segment. There was discussion of assurance for your segmentation efforts – internal and external vulnerability scans as well as penetration testing to assure that portions of the network that are supposed to be isolated from the rest of the network / Internet truly are isolated and remain that way. This is one area that will receive even more attention going forward; if not through more requirements then from your QSA / ISAs.
Being Compliant Does NOT Equal Being Secure
Over and over and over, just about every speaker repeated the mantra that being compliant does not mean that you are actually secure. This is partly to guard against the checklist mentality of compliance, where you do stuff only in order to be able to check the box against the compliance checklist. But it was also to remind people that we aren't infallible – we might be compliant at this particular instant in time but the opportunity to get out of compliance presents itself with the next AV update, new machine added to the network, or vendor software upgrade. Most of the breached merchants in the last few years considered themselves compliant – but apparently not secure. Hence, the continuing emphasis in the DSS on "Compliance as Business as Usual". Look for there to be a new direction in future versions of the standard around the associated processes that keep a merchant compliant – change management, software upgrades, log creation and review, equipment inspection, and so forth.
It appears that we are finally seeing the emergence of Point-to-Point Encryption (P2PE) solutions for merchants. This can be another effective way to reduce the scope of your CDE, particularly when used with tokenization. There are two routes for a vendor to follow when creating a P2PE solution for merchants: validated or unvalidated. In a validated solution, the vendor integrates validated P2PE applications as components in their larger system, has their solution validated by a QSA specializing in P2PE, and then pays the Council to be listed on the validated solutions website. (Similarly for validated applications.) With the upgrade of the P2PE standard to version 2, validated components can now be used by merchants to "roll their own" solution. One benefit of using a validated P2PE solution, or creating your own system from validated components, is that it makes the merchant independent of their acquiring bank; that is, they can move their merchant account to a different acquirer without junking their P2PE system.
Many acquiring banks have a P2PE solution available to their merchants that may not be listed by the Council as validated, but which is equally well vetted by a P2PE QSA. The advantage to the acquirer of this route is that their merchants are more closely tied to them and less able to switch acquirers without starting over with another P2PE solution. The advantage to the merchant is that – assuming they do their due diligence with their acquirer to ensure that the offered solution is properly secure and meets their needs – the recommended solution may cost less than a validated one and may be more closely integrated with the acquirer.
As noted in Mike's posting, I also was enamored with Vancouver – what a lovely city! Even the weather cooperated to produce picture-perfect days. The only thing that marred the stay was that I often found myself apologizing (mostly to taxi drivers and waitresses) for being from such a backward country that didn't issue credit cards with chips... (More on that topic in another posting.)
Joseph D. Tinucci recently moved from the University of Colorado Treasury to Coalfire Systems, Inc., a Colorado-based IT Security Audit and Consulting firm. At CU Joe managed the PCI DSS compliance program for over 175 merchants across four campuses. Now he is helping clients manage their compliance programs from the other side of the desk; he notes that it is a refreshing change of pace and duties to be on the "illuminating side"...
Joe can be reached by email to firstname.lastname@example.org
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