Published on March 4, 2014
PCI DSS 3.0: What the New Regulations Mean to You March 4, 2014 > www.alertlogic.com
Today‟s Presenters Jeff Tutton, MSc., QSA, PA-QSA Chief Information Security Officer Intersec Worldwide > www.alertlogic.com Chris Noell Vice President, Product Management Alert Logic 2
Today Agenda • Why Comply? • PCI DSS 3.0 Basics • Preparing Your Organization • What Next? Logistics • Ask a question anytime using the “Question Box” • Look for slides on the Alert Logic SlideShare account • You‟ll get an email with a link to today‟s recording • Live Tweet today‟s event #AlertLogic_PCI > www.alertlogic.com 3
About Intersec Worldwide http://www.intersecworldwide.com/ Tools, technology and people for security & compliance • PCI qualified QSA, PAQSA • Conduct Incident Response and Forensics • Security engineering firm • Managed service offerings • Remediation team includes: – Policy Review and Development – Managed Network Discovery – Vulnerability Prioritization – More – Network Engineers (CiscoCCIE) – Secure Coding Experts – Penetration Testers – Temp CIO/CISO > www.alertlogic.com 4
Why Comply? > www.alertlogic.com
The End Goal of Compliance is Security Attacks are going to happen > www.alertlogic.com
Most Organizations are Not Fully Compliant Source: Verizon 2014 PCI Compliance Report > www.alertlogic.com 7
PCI DSS 3.0 Basics Part 1: High Level Changes & Clarifications > www.alertlogic.com
PCI DSS 3.0: More Detail, More Precision Two Constituencies: 1. Those who have rigorous, thirdparty PCI DSS assessment = Business as Usual > www.alertlogic.com 2. Those who don‟t (SAQ, assessor who draws scope very narrowly) = Significant Changes
Scoping Change: Service Providers • Service Provider: – Any entity which stores, processes, or transmits cardholder data on a merchant‟s behalf OR – Any entity which manages components such as routers, firewalls, databases, physical security, and/or servers. • If you use a service provider(s), compliance is a shared responsibility – Clarify roles & responsibilities requirement by requirement – If relying on a service provider Report on Compliance, ensure it covers relevant requirements > www.alertlogic.com 10
Scoping Change: Continuous Compliance
Continuous Compliance Implications “…enables an entity to monitor the effectiveness of their security controls on an ongoing basis, and maintain their … compliance … between assessments.” • NOT a change, but a clarification • PCI DSS has always been about continuous compliance • Business objective should be liability mitigation, not passing an assessment – Breach Prevention – Early Detection and Containment – „Safe Harbor‟ > www.alertlogic.com
There are 62 Clarifications in PCI DSS 3.0 • PCI DSS 2.0 requirement -> Testing procedure + Navigating the PCI DSS – – – – Testing procedures = Secret PCI DSS decoder ring Testing procedures are more prescriptive Testing procedures dictate the proper interpretation of the requirement Navigating the PCI DSS provided useful guidance and clarification of intent • PCI DSS 3.0 has reconciled requirements with testing procedure language • PCI DSS 3.0 now includes intent column > www.alertlogic.com
E.g. Requirement 5.2 in PCI DSS 2.0 Navigating the PCI DSS > www.alertlogic.com
E.g. Requirement 5.2 in PCI DSS 3.0 > www.alertlogic.com
PCI DSS 3.0 Basics Part 2: New/Evolving Requirements > www.alertlogic.com
New Requirements: What‟s Big? New Requirements Effective 1/1/2014 5.1.2: Evaluate evolving malware threats for any systems not considered to be commonly affected by malicious software 8.5.1: Service providers with remote access to customer premises must have unique auth for each customer 12.8.5 & 12.9: Maintain information about which PCI DSS requirements are managed by each service provider, and which are managed by the entity 9.9.x: Protect devices that capture payment card data via direct physical interaction with the card from tampering and substitution > www.alertlogic.com 17
New Requirements: What‟s Big? New Requirements Effective 7/1/2015 11.3 Implement a formal methodology for penetration testing 12.9 Service providers must provide a written agreement/ acknowledgement to their customers as specified in 12.8 > www.alertlogic.com 18
Additional New Requirements New Requirements 1.1.3 Current diagram that shows cardholder data flows across systems and networks 2.4 Maintain an inventory of system components in scope for PCI DSS to support development of configuration standards 5.3 Ensure that anti-virus solutions are actively running (formerly in 5.2), and cannot be disabled or altered by users unless specifically authorized by management on a per-case basis 8.6 Where other authentication mechanisms are used (for example, physical or logical security tokens, smart cards, certificates, etc.) that the mechanisms must be linked to an individual account and ensure only the intended user can gain access with that mechanism > www.alertlogic.com 19
Additional New Requirements Continued New Requirements 9.3 Control physical access to sensitive areas for onsite personnel, including a process authorize access, and revoke access immediately upon termination 11.1.2 Align with an already existing testing procedure, for incident response procedures if unauthorized wireless access points are detected 11.3.4 If segmentation is used to isolate the CDE from other networks, perform penetration tests to verify that the segmentation methods are operational and effective 11.5.1 Implement a process to respond to any alerts generated by the change-detection mechanism 6.5.10 Coding practices to protect against broken authorization and session management* * Effective 7/1/2015 > www.alertlogic.com 20
Avoid These Misconceptions MYTH! System inventory only Correct: It includes ALL network includes the main application servers MYTH! Vulnerability scans are only required quarterly MYTH! Code reviews are enough for publicfacing web applications under Requirement 6.6 > www.alertlogic.com devices, servers, etc. within the CDE network segments Correct: They‟re also required after any “significant” change – you should define “significant” in your procedures! Correct: Clarified guidance requires an application vulnerability security assessment tool (or method), or a web application firewall (WAF) after “any” changes – this clarification is important
Preparing Your Organization > www.alertlogic.com
Preparation Checklist 1. Produce and validate a full listing of components within the CDE 2. Produce/update cardholder data flow diagrams 3. Perform (or have performed) a DSS 3.0 gap analysis Review and update penetration testing methodology and service provider contracts Review the requirements under 6.6 to make sure you are meeting them fully 4. 5. > www.alertlogic.com
What to do with Existing PCI 2.0 Reports? • Review them, learn from them and use as starting point • Conduct a Gap from 2.0 to 3.0 • Start asap • Keep them! Store for 7 years > www.alertlogic.com 24
Who to Involve? Within Your Organization • All IT resources • • • Use External Resources • To guide your internal resources • All security reviews • Penetration testing • Secure code reviews Network & Systems Applications & Database Development • Non-IT • • • • > www.alertlogic.com HR & Legal Accounting & Finance Customer Service & Training Exec Team 25
What‟s Next? > www.alertlogic.com
Next Steps • Complete gap analysis before formal assessment • Find your weaknesses and fail points … soon! • Bring all Security & Compliance “skeletons” out of the closet • Consider separate PCI Gap & PCI Assessment teams – It’s not required but fresh eyes usually help > www.alertlogic.com 27
Join Us on March 6th PCI DSS Solutions from Alert Logic • http://http://alrt.co/1jMsIxF > www.alertlogic.com 28
Good Sources for More Information • Intersec Worldwide - http://www.intersecww.com/compliance/pci-dss/ • Alert Logic - https://www.alertlogic.com/solutions/compliance/pci-dss-compliance/ • PCI Security Standards Council: https://www.pcisecuritystandards.org/ • Visa Cardholder Information Security Program: http://usa.visa.com/merchants/risk_management/cisp_overview.html • Mastercard Site Data Protection Program: http://www.mastercard.com/us/company/en/whatwedo/site_data_protection.html • American Express Data Security Standard: https://www.americanexpress.com/in/content/merchant/support/data-security/merchantinformation.html • Discover Information Security and Compliance: http://www.discovernetwork.com/merchants/data-security/disc.html > www.alertlogic.com 29
Thank you! Q&A @Intersecww info@IntersecWW.com @alertlogic firstname.lastname@example.org IntersecWW.com/about/blog http://www.alertlogic.com/resources/blog/ > www.alertlogic.com
APPENDIX Evolving Requirements Details > www.alertlogic.com 31
Evolving Requirements Details PCI DSS 3.0 Requirement Change Comment 1.1.3 Include Cardholder Data Flows on Network Diagram Generally Required to Properly Scope CDE 2.4 Maintain Inventory of In-Scope System Components One of the First Questions An Assessor Should Ask 5.1.2 Requirement to Evaluate Threats to Systems Not Commonly Affected by Malware Implicit in PCI DSS 2.0 5.3 New Requirement to Ensure AV is Actively Implicitly Covered By PCI DSS Running and Cannot Be Disabled/Altered 2.0 Given Requirement 1.4 by Users Testing Procedure 6.5.10 New requirement for coding practices to protect against broken authentication and session management > www.alertlogic.com Back-to-the-Future – This was included in PCI DSS 1.2. 3.0 has more rigor on testing procedures than 1.2 version.
Evolving Requirements Details PCI DSS 3.0 Requirement 8.2.3 Change Combined minimum password complexity and strength requirements into single requirement, and increased flexibility for alternatives that meet the equivalent complexity and strength. Comment Using alternatives of equal strength was one of the most common compensating controls NIST SP 800-63-1 for understanding equivalent password strength variability for passwords/phrases of different formats. 8.5.1 > www.alertlogic.com New requirement for service providers with remote access to customer premises, to use unique Authentication credentials for each customer. Effective July 1, 2015 Logical application of PCI DSS v2.0’s Requirements 8.1 and 8.2.
Evolving Requirements Details PCI DSS 3.0 Requirement Change Comment 8.6 New requirement where other Logical extension of PCI DSS authentication mechanisms are used ( v2.0 Requirement 8.1 and For example, physical or logical 8.3 guidance. security tokens, smart cards, certificates, etc.) that the mechanisms must be linked to an individual account and ensure only the intended user can gain access with that Mechanism. 9.3 New requirement to control physical access to sensitive areas for onsite personnel, including a process to authorize access, and revoke access immediately upon termination > www.alertlogic.com Logical application of PCI DSS v2.0’s Requirements 9.1 and 8.5.4.
Evolving Requirements Details PCI DSS 3.0 Requirement 9.9 Change New requirements to protect devices that capture payment card data via direct physical interaction with the card from tampering and substitution. Comment Significant new requirement which will involve training personnel to look for evidence of skimming attacks. Effective July 1, 2015 10.2.5 Enhanced requirement to include changes to identification and authentication mechanisms (including creation of new accounts, elevation of privileges), and all changes, additions and deletions to accounts with root or administrative access. Clarification of a rather ambiguous logging requirement. 10.2.6 Enhanced requirement to include stopping or pausing of the audit logs. Could be a significant change or a nonevent depending on what your applications support. > www.alertlogic.com
Evolving Requirements Details PCI DSS 3.0 Requirement 11.1 Change Comment > www.alertlogic.com Detecting unauthorized wireless access points (11.1) implicitly requires an inventory of authorized ones. New requirement to implement a methodology for penetration testing. Significant expansion of penetration testing requirement. Effective July 1, 2015. 11.3 / 11.3.4 Enhanced requirement to include an inventory of authorized wireless access points and a business justification (11.1.1) and added new requirement 11.1.2 for incident response procedures if unauthorized wireless access points are detected. Almost certain to require budget increases for testing and remediation. PCI DSS v2.0 already covered 11.1.2 under Testing Procedure 11.1.e.
Evolving Requirements PCI DSS 3.0 Requirement Change 11.5.1 New requirement to implement a process to respond to any alerts generated by the change-detection mechanism (supports 11.5) Clarification. Covered as part of the 12.9.3 Testing Procedure. 12.2 Expanded frequency of the risk assessment from at least annually to include updates after significant changes to the environment. Most organizations will need to update change management/governance procedures. 12.8.5 New requirement to maintain information about which PCI DSS requirements are managed by Each service provider, and which are managed by the entity. Knowledge previously required for compliance. Formal documentation now required. > www.alertlogic.com Comment
Evolving Requirements Details PCI DSS 3.0 Requirement 12.9 Change New requirement for service providers to provide the written agreement/ acknowledgment to their customers as specified at requirement 12.8. Effective July 1, 2015 > www.alertlogic.com Comment Service Provider requirement only. Should facilitate compliance with 12.8.2
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