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PCI COMPLIANCE - Lessons Learnt. Greg Swedosh HP NonStop Security & PCI Compliance Consultant Knightcraft Technology. Lessons Learnt from Recent PCI Projects. Two Tier 1 Organisations

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PCI COMPLIANCE - Lessons Learnt

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PCI COMPLIANCE - Lessons Learnt

Greg Swedosh

HP NonStop Security & PCI Compliance Consultant

Knightcraft Technology


Lessons Learnt from Recent PCI Projects

  • Two Tier 1 Organisations

    • Knightcraft recently was involved in the PCI DSS Compliance projects of two large Australian Tier 1 organisations.

    • Both started with non-compliant methods, system configurations and documentation.

    • Both had directive from senior management that PCI Compliance was a non-negotiable for the organisation.

    • Here are some lessons learnt by the organisations during the process.


The Path to PCI Compliance


PCI DSS – A Corporate Priority

  • PCI Compliance must be a strategic priority

    • PCI Compliance is not just about ticking a few boxes and getting a pass. It is about mitigating the risk of credit card fraud.

    • Achieving and maintaining PCI compliance must be a directive from senior management within the organisation. When conflict arises (which it will), somebody needs to have the power to ensure PCI compliance remains a top priority.

    • The card acquirers (i.e. the banks) are now starting to help focus the minds of corporate executives by imposing multi-million dollar fines, if sufficient progress is not being made.


Appropriate Budget

  • Allocate sufficient budget

    • You will need appropriate budget for:

      • Extra resources. The existing staff probably already have a large workload. You will need more people.

      • Extra tools

        • Software to satisfy security/audit requirements

        • Compliance monitoring tools to track progress

      • Expertise

        • Provide required PCI training to internal security staff

        • Bringing in appropriate expertise will provide direction. Compliance will be achieved in a quicker and more cost effective way.

        • Liaise closely with your QSA

  • The cost of fraud is far greater than the cost of compliance


Run as a Program

  • PCI Compliance is not a “one off” Project

    • Initial compliance needs to be set up as a defined project with end date, appropriate budget and resources to do the job,

    • BUT…

    • there needs to be an ongoing PCI compliance plan

      • Once compliant, an organisation must remain compliant. There is a PCI DSS assessment every year.

      • Tools to track compliance from one year to the next make the annual effort easier and more accurate e.g. RSA Archer

        • Each requirement is documented as to how it complied this year, so same documentation, procedures, config can be easily identified and verified next year


Common Obstacles


Competing Priorities

  • The Business v PCI DSS

    • In both organisations PCI was labeled as top priority, but issues arose where the business forced PCI to the back seat

      • Software Upgrades

      • Hardware Upgrades

      • Other planned projects causing delays


Resistance to Change

  • Old dogs, New tricks

    • Changes to existing procedures

      • Different commands and different screens

    • Reduction in the use of privileged userids

      • Entrenched use of super.super/root and application userids on a day to day basis

      • The concept of “least privilege required”

    • Changes to access rights

      • The “need” to access and modify critical files

      • Lack of willingness to embrace change management

    • Blame the security

      • If something doesn’t work, blame the new security


Lack of Resources

  • Too much work to be done by too few

    • Systems managed by very small teams

    • Project scheduled with disregard for how much work systems/application teams already do

    • Lack of continuity as staff dragged off for support or other implementation work

    • Many managers, not enough workers

    • Too many meetings, not enough work

      • With so many people “managing”, too much time can be spent keeping them “up to date”, rather than actually doing the work


Lack of Separation of Duties

  • The one stop shop

    • In-house system tools that have been used for years, now questioned as to their acceptability

      • Designed, coded, implemented and used by same person

    • Security monitoring by system manager

      • Those with greatest power and access to the system responsible for monitoring their own access

    • Security managed by application support team

      • Those with knowledge and access to modify application also responsible for managing security around the application


Documentation

  • There’s so much… where do I start?

    • The most time consuming work effort required is documentation.

    • Despite knowing it needs to be done and having it up front in the plan, it still gets pushed to the back of the queue.

    • There is no shortcut. Most requirements have a documentation component and it must be satisfied for the requirement to be “In Place”.


Lack of Security Ownership

  • Who decides who can access what?

    • Security managed by system adminstrators

    • Access provided on request without questioning whether it is really required

    • The use of “trust” as a mechanism for ensuring that no unauthorized actions are taken

    • Nobody ultimately responsible for system security


Security Report Analysis

  • Who will read the reports?

    • Setting up auditing and session capture is easy, but who will read the reports?

      • If reports and session logs are sent off box, the technical knowledge may not be there to really determine what has happened on the system.

      • If use of privileged userids is excessive, reading through user sessions is an onerous task.

      • This job is boring. Nobody wants to do it.

      • The answer is to try and minimize the amount of reports to be analysed as much as possible

        • Minimize use of privileged userids

        • Automate report analysis as much as possible


Steps to PCI Compliance


Steps to PCI Compliance

  • A checklist for success

    • The following will help you achieve and maintain PCI compliance

      • Set ownership of PCI compliance with very senior management

      • Approach PCI DSS as an ongoing program, not just a finite project

      • Use appropriate tools to track compliance going forward

      • Communicate clearly and often to all staff of the importance of PCI compliance

      • Educate staff on how changes will affect them in their daily job

      • Allocate appropriate budget

      • Ensure you have appropriate resources for the job

      • Make documentation a high priority - It is the biggest job

      • Bring in expertise to help you in your task – QSA, Consultants, Staff Training

      • Identify personnel for critical roles – security ownership, report analysis

      • Make realistic schedules - factor in other projects and unexpected delays

      • Expect the path to be bumpy


Steps to PCI Compliance

  • The Definitive Resource

    • PCI Compliance for HP NonStop Servers – Technical white paper

      • Download the latest version from www.knightcraft.com

      • Technical white paper written by Knightcraft Technology with Witham Laboratories (QSA)

      • Details what you need to do for EVERY requirement of PCI DSS and what a QSA will look for

      • Internationally recognised as the leading resource on PCI compliance for the NonStop

      • Includes section on evaluating security software to meet your PCI compliance needs


Knightcraft Technology

  • HP NonStop Security and PCI Compliance Specialists

Knightcraft Services

PCI DSS Consultancy

  • Achieve compliance in a fast, reliable and cost-effective manner

    Security Implementation

  • Best practices HP NonStop Security configuration

    • Safeguard, OSS and XYGATE specialists

      Documentation

  • PCI DSS required documentation. We know what’s required.

PCI Compliance

Email: [email protected]

See our website: www.knightcraft.com


Thank you


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