Security Basics mailing list archives
Re: Any PCI Gurus?
From: Ben <sixtwelveohtwo () gmail com>
Date: Fri, 14 Jan 2011 15:58:37 -0800
Hi Shankl, I'm no QSA or PCI consultant (apply all normal disclaimers here), but I think I can provide some insight on most of these. On Thu, Jan 13, 2011 at 4:38 PM, Shankl Shankl <shankl () hotmail com> wrote:
Heres a little scenario that I wanted to throw out there and get an opinion on by someone who knows PCI. I am starting to learn but couldn't help with this problem because I've never assisted in a PCI audit... (I would think this problem has been encountered by many companies that make network appliances) ====== Background ======= 1) Company A is a small company (only 5 employees) 2) They provide a service which requires their customer, Company B, to install a small network appliance on their LAN in order to collect data from their onsite mechanical equipment. 3) Operating data is then pulled from these mechanical systems and then dumped to a remote server which processes the data and provides a dashboard for the customer to view (via SSL). 4) Company B bought a license for this service and was also handed over the keys to administer accounts and decide which employees it would like to give access to. 5) Now let’s say that Company B typically processes credit card payments locally and sends transaction data through their local LAN on its way out to their payment processor. ====== Problems ======= 1) Company A does not take credit cards and is not required to be PCI compliant however they do provide a service which requires their network appliance to be installed on Company B’s network. 2) In recent days Company A has come to the conclusion that in some of Company B’s newly acquired satellite offices, credit card data is being forwarded across the LAN in a variety of ways (some of which do not look to be secure/encrypted). 3) In addition, several of these satellite offices are running consumer grade routers (ie: Linksys, Netgear) providing little in the way of segmentation. 4)Company A would like to avoid being “In Scope” and having to charge the client for consulting fees. ====== Questions ======= 1) For the smaller satellite offices what might be a simple fix?
Segmentation. Segmentation. Perhaps a little more segmentation. Proverbial "Company B" should really be segmenting their traffic to keep CHD away from other devices to reduce scope as much as possible. The other possibility, though it lands on the opposite end of the simplicity scale, is tokenization. This is a fairly new method of reducing scope and is a much larger undertaking probably best left alone in smaller environments.
2) Does segregation provide an easy way to kick devices out of scope for PCI audits?
Yes, very much so. (See above.) If we're still talking about consumer-grade devices, segmentation that meets standard may not be as easily achieved. Most entry-level business class equipment offers simple VLANs and ACLs that quite easily meet the requirements for network segmentation.
3) Would it be recommended/possible to have a firm produce a report which could be handed to an auditor and prove “Out of Scope” prior to being dragged into one of these audits?
It would probably be possible to get a QSA to do a brief engagement to confirm whether or not "Company A's" devices are "in scope" at "Company B," but the QSA that "Company B" is using for their own audit should be able to define this, as well.
4) Could the network appliance be designed/situated in such a way as to be “out of scope” or at least easily verifiable as compliant even if it was sitting on the same logical subnet where the card data traffic was moving across?
While it may not seem like it, this is a fairly ambiguous question. The best way to situate the appliance to be out of scope is to put it on a different network segment. Whether or not the appliance itself is compliant is an even most dubious question. This depends heavily on what the device is, does, and can do. The only way that (this is where I'll admit my experience gets a bit fuzzy) a device can be said to be "compliant" is based upon its configuration or ability to meet configuration requirements. Is this what this particular question centers around?
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Current thread:
- Any PCI Gurus? Shankl Shankl (Jan 14)
- Re: Any PCI Gurus? Ben (Jan 18)
- RE: Any PCI Gurus? Matthew Reed (Jan 18)
- Re: Any PCI Gurus? Eric C. Lukens (Jan 18)
- Re: Any PCI Gurus? Ben (Jan 18)