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Payment Card Industry
Data Security Standards
ISACA January 8, 2013
IT Auditor at Cintas Corporation Internal Audit Department Internal Security Assessor (ISA) Certification
September 2010 Annual re-certification Currently responsible for SOX IT and PCI
testing as well various Corporate audits Board of Governors, IIA Cincinnati Chapter
Cheryl Becker
The PCI DSS represents a common set of industry tools and measurements to help ensure the safe handling of sensitive information.
The standard provides an actionable framework for developing a robust account data security process - including preventing, detecting and reacting to security incidents.
Applies to any entity that stores, processes and/or transmits CHD.
What is PCI DSS?
PCI is not government legislation. It is an industry regulation.
The major Card Brands (Visa, MC, Discover, Amex) decided to create regulations which were initially agreed upon by the Card Brands in 2004.
PCI DSS version 1 is dated December 2004. On June 30, 2005, the regulations took
effect. The PCI Security Standards Council came
into existence in 2006.
History Lesson
The Council became responsible for the development, management, education and awareness of the PCI Data Security Standards.
Each of the Card Brands (Visa, MC, Discover, Amex, JCB) have their own compliance programs in accordance with their own security risk management policies as well as their own definitions of the “levels” and their own penalizing/fining procedures for companies who have a breach.
PCI Security Standards Council
4◦ Little credit card business◦ Some Card Brands do not have this level◦ Annual Compliance Validation
3◦ Less than a million credit card transactions◦ Some Card Brands do not have this level◦ Annual Self-Assessment
Merchant Levels Overview
2◦ Millions (1+ to <6) credit card transactions◦ All Card Brands have this level◦ Must internally audit with a PCI certified Internal
Security Assessor (ISA) using PCI DSS 1
◦ Many millions (2.5+ to 6+) credit card transactions◦ All Card Brands have this level◦ Must audit either using a PCI certified external
Qualified Security Assessor (QSA) OR Internal Audit with ISA certification using PCI DSS
Merchant Levels Overview
The PCI SSC Sponsor Company Internal Security Assessor Program is a PCI DSS training and qualification program for eligible internal audit security professionals. The course helps participants improve their organization's understanding of PCI DSS and validate and maintain ongoing compliance through:◦ Enhancing the quality, reliability, and consistency of
internal PCI DSS self-assessments ◦ Supporting the consistent and proper application of PCI
DSS measures and controls ◦ Effectively facilitating interactions with QSAs
https://www.pcisecuritystandards.org/index.php
PCI ISA Training Program
Version 2.0 as of October 2010 Version will be on a three year basis The PCI documentation (end result) has
changed every year
PCI DSS Versioning
Build and Maintain a Secure Network Protect Card Holder Data Maintain a Vulnerability Management
Program Implement Strong Access Control Measures Regularly Monitor and Test Networks Maintain an Information Security Policy
PCI DSS Six Goals
1) Install and Maintain a firewall configuration to protect Card Holder Data (CHD)◦ Firewall and Router configuration standards◦ Review Network Diagram◦ Firewall and Router connections are restricted
(inbound/outbound traffic)◦ No direct internet connection to CHD (DMZ)
2) Do not use vendor supplied defaults◦ Attempt to sign on with defaults◦ Hardening standards and system configuration◦ Non-console admin access is encrypted
12 Requirements
3) Protect stored CHD◦ Retention Policy and Procedures◦ Quarterly process for deleting stored CHD ◦ Sample incoming transactions, logs, history files,
trace files, database schemas and content◦ Do not store full track, CVV or PIN◦ Render PAN unreadable (mask/truncate)◦ Encryption and key management
4) Encrypt transmission of CHD◦ Verify encryption and encryption strength◦ Verify wireless is industry best practice (no WEP)
12 Requirements
5) Use and regularly update Antivirus software◦ All system have AV◦ AV is current, actively running and logging
6) Develop and maintain secure systems and applications◦ Patch management – current within one month◦ ID new security vulnerabilities with risk rating◦ Custom code is reviewed prior to release◦ Change management process◦ Developers are trained in secure coding
techniques
12 Requirements
7) Restrict access to CHD by need-to-know◦ Review access policies◦ Confirm access rights for privileged users◦ Confirm access controls are in place◦ Confirm access controls default with “deny-all”
8) Assign a unique ID to each user◦ Verify all users have a unique ID◦ Verify authentication with ID/PW combination◦ Verify two-factor authentication for remote access◦ Verify terminated users are deleted◦ Inspect configurations for PW controls
12 Requirements
9) Restrict physical access to CHD◦ Access to computer rooms and data centers◦ Video cameras are in place and video is secure◦ Network jacks are secure – not in visitor area◦ Process for assigning badges◦ Storage locations are secure (offsite media)
10) Track and monitor all access to network resources◦ Review audit trails – actions, time, date, user, etc.◦ Time server updates and distribution◦ Process to review security logs
12 Requirements
11) Regularly test security systems◦ Test for wireless access points◦ Internal and external network vulnerability scans◦ Internal and external penetration testing annually◦ File integrity monitoring tools are used
12) Maintain security policies◦ Policies are reviewed at least annually◦ Explicit approval is required for access◦ Auto disconnect for inactivity-internal and remote◦ Security awareness program is in place◦ Incident Response Plan
12 Requirements
~260 tests◦ PCI DSS gives both the requirement and the test◦ Every test has to have an answer◦ Every bullet within each test must have an
answer◦ If the requirement is not in place, a target date
and comments must be made◦ If there are compensating controls, a
Compensating Control Worksheet must be completed
PCI DSS Tests
Attestation of Compliance Executive Summary Score Report on
Compliance Test Procedures Score Sheet Report on
Compliance
PCI Documentation
This is the document that is submitted to the appropriate companies◦ Scanning vendor◦ Merchant (i.e. Bank)◦ Card Brand Company (i.e. Amex)
Signed by ISA/QSA and Officers of the Company
Brief overview of Company and Cardholder Data Environment◦ Not a website copy/paste◦ My summation of the company (business, DC, locs)
Attestation of Compliance
Brief overview of how the company stores, processes and/or transmits cardholder data◦ Terminals◦ Applications◦ Third parties
State if we are compliant All 12 Requirements are listed stating “in
place” or “not in place” and “special” like N/A
At the bottom explain special – N/A may be ‘not a service provider’
Attestation of Compliance
Within the Attestation of Compliance The “special” column is where to state if it
is a compensating control “NOTE: Only companies that have
undertaken a risk analysis and have legitimate technological or documented business constraints can consider the use of compensating controls to achieve compliance”
Ex: cannot do 7 character pw on mainframe
Compensating Control Worksheet
Detailed overview of CHDE – explain the flow from ‘swipe’ ◦ Phone orders◦ Online orders◦ Monthly charges◦ Any other way CHD is processed
Network diagram prepared by ISA/QSA Validate and explain scope – flat vs.
segment Validate myself
Executive Summary Score Report on Compliance
Explain the environment◦ Personnel◦ Payment channels◦ IT Environment◦ Locations
Explain sampling method Exclusions and why they were excluded Wholly-owned Entities International locations Wireless Environment
Executive Summary Score Report on Compliance
Service providers Third-party applications Individuals interviewed with titles List of documentation reviewed My contact information Quarterly scan information Findings and observations
Executive Summary Score Report on Compliance
How each control was tested◦ Observation – configuration or process◦ Sampling◦ Interview with whom◦ Document reviews
Test Procedures Score Sheet Report on Compliance
Give yourself enough time to complete the final reports
Answer all of the points in each test Know your scope Inventory the environment Use a firewall to segment If you are getting your QSA/ISA, complete
the training and study Users/coworkers/employees do not
understand IT security (i.e. email)
Lessons Learned
