CARD BREACHES ARE ON THE RISE
2010 Security Breaches Food and Beverage – 57% Retail – 18% Hospitality – 10% Financial – 6% Government ‐ 6% M O S S A D A M S L L P| 5 Source: Trustwave’s Global Security Report 2010 Education – 1% Construction ‐ 1% Entertainment ‐ 1%NOTABLE CARD BREACHES
• TJX Companies – 2007 – Hackers compromised wireless network to steal information on approximately 94 million card network to steal information on approximately 94 million card transactions. • Heartland Payment Systems – 2008 – Hackers attacked system used to process card transactions. Inserted malware. Up to 100+ million transactions compromised. • Lush Cosmetics – 2010 – Ecommerce website hacked. 5,000 card transactions accessed. Led to shutdown of their
card transactions accessed. Led to shutdown of their ecommerce operations.
• PCI Security Standards Council (PCI SSC or the Council) founded in 2006 is responsible for the development,
PCI OVERVIEW
management, education, and awareness of the PCI Security Standards. • PCI Data Security Standard (PCI DSS) is a comprehensive set of international security requirements for protecting cardholder data. • Payment Application Data Security Standard (PA‐DSS) is a set of requirements for software vendors to develop secure M O S S A D A M S L L P| 7 SLIDE7 q p payment applications. • PCI PIN Transaction Security (PCI PTS) is a set of requirements for device vendors and manufacturers for all personal identification number (PIN) terminals, including POS devices, encrypting PIN pads, and unattended payment terminals. • Not a government regulation, but an industry regulation. • Purpose is to help prevent credit card fraud and maintain publicPCI OVERVIEW
p p p p confidence in payment cards. • Applies to all entities that process, store, or transmit payment card information need to comply (Primary Account Number “PAN” is the deciding factor.) • CaArd transaction players: card brands, merchants, service providers, acquirers, and issuers.• Effective compliance dates varies depending on merchant level orEffective compliance dates varies depending on merchant level or service provider level and card brand. All deadline enforcement will come from the acquiring bank.
THE PAYMENT CARD TRANSACTION
Payment Payment Brand Network Acquirer (Merchant Bank) Issuer (Consumer Bank) Service Provider M O S S A D A M S L L P| 9 Merchant CardholderTHE ACQUIRER’S ROLE
•
Acquirers are responsible for:
Acquirers are responsible for:
o
Ensuring their merchants are PCI DSS compliant
o
Managing merchant communications
o
Working with their Level 1 merchants until full
compliance has been validated:
Merchants are NOT COMPLIANT UNTIL ALL REQUIREMENTS have been met and validated
have been met and validated
Acquirer is responsible for providing Visa their merchants’ compliance status
HIGHLIGHTS OF CHANGES
V1.2 – V2.0
M O S S A D A M S L L P| 17
HIGHLIGHTS OF CHANGES –
V1.2 TO V2.0
HIGHLIGHTS OF CHANGES –
V1.2 TO V2.0
•
Added guidance on test procedures and new technologies,
Added guidance on test procedures and new technologies,
such as virtualization and private cloud adoption
•
Recognition of small merchant environments – be more
flexible
•
Eliminate redundant sub‐requirements
M O S S A D A M S L L P| 19HIGHLIGHTS OF CHANGES –
V1.2 TO V2.0 - EXAMPLES
•
Virtualization – req 2.2.1
Virtualization req 2.2.1
HIGHLIGHTS OF CHANGES –
V1.2 TO V2.0 - EXAMPLES
•
Risk based approach for addressing
Risk based approach for addressing
vulnerabilities ‐ req 6.2 & 12.1.2
o Assign risk ranking to vulnerabilities o Also impact reg 6.5.6 and 11.2 o Implementation date – July 1, 2012M O S S A D A M S L L P| 21
KEY COMPLIANCE TIPS
M O S S A D A M S L L P| 23
KEY COMPLIANCE TIPS
KEY COMPLIANCE TIPS (CONT.)
• Encrypt databases/files prior to committing them to backup yp / p g p tape/removable media • Install A/V on your database servers that store cardholder data (or document compensating controls) • Segment (“cocoon”) your CDE and use two‐factor authentication for remote access (internal pen testing is not ) M O S S A D A M S L L P| 25 necessary) • Institute a verification step for non‐face‐to‐face password resets (e.g., employee ID)KEY COMPLIANCE TIPS (CONT.)
•
In virtualized environments, limit the number of mixed
In virtualized environments, limit the number of mixed
mode servers (use separate partitions for each virtual
host)
•
Implement POS systems with point‐to‐point encryption
(P2PE) functionality (reduces scope)
•
Conduct quarterly vulnerability scans and address
Conduct quarterly vulnerability scans and address
vulnerabilities immediately
LEVERAGING PCI DSS AUDIT
•
Documentation collected for PCI‐DSS requirements can
Documentation collected for PCI DSS requirements can
be repurposed for other audits:
o Test results completed for PCI requirements can be used or relied upon by SAS 70/SSAE16 auditors
o Policies and templates developed for PCI compliance such as information security policies and user request forms can be used for systems without cardholder data
M O S S A D A M S L L P| 29 can be used for systems without cardholder data
o Security awareness training and acceptable use policies can fill possible gaps in existing Human Resources polices
LEVERAGING PCI DSS AUDIT
Description of Good Practices PCI‐DSS v2 ISO 27002 HIPAA
LEVERAGING PCI DSS AUDIT
Francis Tam, CPA, CISA, CISM, CITP, CRISC, PCI QSA
QUESTIONS?
Managing Director, PCI Practice Leader
(310) 295‐3852
[email protected]
Kevin Villanueva,
CISSP, CISA, CISM, PCI QSA
Senior Manager IT Security Practice Leader
Kevin Villanueva, CISSP, CISA, CISM, PCI QSA
Senior Manager, IT Security Practice Leader