kevin r perry august 12, 2014. part 1: high level changes & clarifications
TRANSCRIPT
NASACT 2014 Annual Conference
PCI DSS 3.0: What the New Regulations Mean to
You
Kevin R PerryAugust 12, 2014
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
“Continuous Compliance” Implications
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’
“…enables an entity to monitor the effectiveness of their security controls on an
ongoing basis, and maintain their … compliance … between assessments.”
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
New Requirements: What’s Big?
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
New Requirements Effective 1/1/2014
New Requirements: What’s Big?
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
New Requirements Effective 7/1/2015
Additional New Requirements1.1.3 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) that the mechanisms must be linked to an individual account and ensure only the intended user can gain access with that mechanism
New Requirements
Additional New Requirements (Cont.)
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*
New Requirements
* Effective 7/1/2015
Avoid These Misconceptions
MYTH!
System inventory only includes the main application servers
Correct: It includes ALL network devices (routers, firewalls, switches), servers, etc. within the CDE network segments
MYTH!
Vulnerability scans are only required quarterly
Correct: They’re also required after any “significant” change – you should define “significant” in your procedures!
Who to Involve?
Within Our Organization
• All IT resources Desktop & Security Network & Server Applications &
Database Development
• Non-IT HR & Legal Accounting & Finance Customer Service &
Training Executive Team
Use External Resources To guide your internal
resources All security reviews QSA for scans Penetration testing
Evolving Requirements DetailsPCI DSS 3.0 Requireme
nt
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 Running and Cannot Be Disabled/Altered by Users
Implicitly Covered By PCI DSS 2.0 Given Requirement 1.4 Testing Procedure
6.5.10 New requirement for coding practices to protect against broken authentication and session management
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 Requiremen
t
Change Comment
8.2.3 Combined minimum password complexity and strength requirements into single requirement, and increased flexibility for alternatives that meet the equivalent complexity and strength.
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 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 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.
Logical extension of PCI DSS v2.0 Requirement 8.1 and 8.3 guidance.
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
Logical application of PCI DSS v2.0’s Requirements 9.1 and 8.5.4.
Evolving Requirements DetailsPCI DSS 3.0 Requiremen
t
Change Comment
9.9 New requirements to protect devices that capture payment card datavia direct physical interaction with the card from tampering and substitution.
Effective July 1, 2015
Significant new requirement which will involve training personnel to look for evidence of skimming attacks.
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.
Evolving Requirements DetailsPCI DSS 3.0 Requireme
nt
Change Comment
11.1 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.
Detecting unauthorized wireless access points (11.1) implicitly requires an inventory of authorized ones.
PCI DSS v2.0 already covered 11.1.2 under Testing Procedure 11.1.e.
11.3 / 11.3.4 New requirement to implement a methodology for penetration testing.
Effective July 1, 2015.
Significant expansion of penetration testing requirement.
Almost certain to require budget increases for testing and remediation.
Evolving Requirements
PCI DSS 3.0
Requirement
Change Comment
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.
Evolving Requirements Details
PCI DSS 3.0
Requirement
Change Comment
12.9 New requirement for service providers to provide the written agreement/ acknowledgmentto their customers as specified at requirement 12.8.
Effective July 1, 2015
Service Provider requirement only. Should facilitate compliance with 12.8.2