Re: PCI DSS Compliance

[Pete Herzog <lists () isecom org>]

Lyal, all,

Sorry for the delay-- I had vacation.

Lyal Collins wrote:
> I don't think it's a question of the PCI document being right or wrong, but
> of compliance to a set of domumented requirements in order to either stay in
> business or minimise financial impact on a company if a security breach
> involving credit cards occurs.

This is indeed a problem where compliance is seen as protection.  The 
two are very often not the same.  Why accept the PCI document as one
that minimizes financial impact, privacy breaches, etc. if the premise
only scratches the surface of the definition of protection?  We cannot 
simply accept that products, blacklists, and the products that love them 
are to be regulations.  Compliance should be simply the do's and don'ts 
of protection and loss controls with metrics to assure compliance. 
Remember that best practices are not best for all.  The protection 
requirements should be documented but not the process of achieving them.

> PCI requires, among 190+ other things, vuln scanning of all internet facing
> systems, and those internal systems that process cardholder data, not the
> entire internal network.  PCI also requires an annual pen-test, to attempt
> to exploit  scanning-discovered vulnerabilities.  Of course you may choose
> to scan the rest of the entire network as part of enterprise security
> management.

Pen tests are another thing that are also poor security tests.
Requiring a pen test is barely better than requiring a vulnerability
scan of systems that hold cardholder data.  But maybe I don't understand 
what you mean by pen test.  To me it's a test for exploiting weaknesses 
in a network to raise privileges and meet a pre-assigned goal (such as 
card member data).

In that case a pen test is big mistake.  A black box pen test can only 
ever be favorable to the client as opposed to one where the tester has 
more information about the network, the systems, the processes, and the 
alert/alarm profile.  The latter is more beneficial to the card holders 
and the card issuers because it would mean something about testing 
protection and loss controls and not just the tester's skills.

Sure PCI is about compliance but takes the wrong approach to be about
protection and loss controls.  For example, just asking for a 
third-party every year is such a huge generalization because if you 
consider the speed of progress, then shouldn't sites with more 
interactions, a greater scope, need more frequent audits than smaller 
ones?  If this was based on a metric, you could assure audits were done 
whenever the metric reached an unsavory number.

I know this document came out to improve things but it's still far from 
that goal.

Sincerely,
-pete.