Tag: ISO27001 (Page 1 of 2)

The Biggest (Real) Myths of PCI-DSS: Part 3

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OK, we are down to the final 3 Real Myths of PCI-DSS, so here we go!

Real Myth 8: PCI-DSS gets easier and cheaper every year

This is quite understandable, seeing that the idea behind PCI-DSS , to many is to do once and be done with it. And in a sense, this is actually borderline correct. If you learn how to ride a bike at the start, you may need to get your Dad to teach you how to ride it so he is holding you for a while. After a while (sometimes, for some, maybe six years), you are able to ride the bike on your own and you don’t need your Dad hanging around anymore. So it’s the same. Except, replace the bike with PCI activities and your Dad with outsourced consultants or implementers.

The great thing about PCI-DSS is that it doesn’t dictate you to go out and purchase expensive services. In fact, the more you “in-source” the less costly your PCI will cost you (in terms of money going out of your company). If for the first year, you paid maybe 20K for all your penetration testing services – after 2 or 3 years, you decide to set up an internal InfoSec team to do these activities – done. You don’t have that 20K output anymore, and you have a team of pentesters to do it. (Of course, the question comes – how much are you paying your pentesters’ salary?)

However, whether it becomes easier/cheaper is probably not the case. You see, the first time you go through PCI-DSS, you are in what we call, First Time Certification stage. In this part, some of the requirements, such as quarterly ASV scan, quarterly IVA, half yearly firewall reviews, 12 months of log archives etc does not apply. And you go, huh? Why? Because you get a free pass, that’s why. In the first time cert, you simply have to do one iteration of these activities. For instance, the ASV scan, you just need to demonstrate one cycle of scan for all in scope systems. Your first time cert time range should be around 6 months…so, in this case, you could run an ASV scan one time, submit that as evidence for certification and get certified.

Once you are certified, keep an eye on the date when you signed off your AoC. 12 months from that date is your expiry, so that is your maintenance year. Your maintenance year is then divided into 4 quarters and you will need to ensure your annual, quarterly, bi-weekly, weekly, daily activities are done accordingly. So instead of ONE ASV scan, you now have 4. For each of your IP. Instead of one Internal VA, you have 4. Instead of one segment PT, you have 2. Instead of 1 Firewall Review, you now have 2. You get the gist. So for those who wonder if it gets easier in the second, third, fourth year, there is a rude shock. Furthermore, your scope may increase based on your growth so instead of testing 10 systems, your second year may test 20. Additionally, knowledge may also not be kept because there your IT team or compliance team may leave. That’s reality, so you are typically back where you started. So now you know. PCI-DSS is not unlike a marriage. You need to keep working on it to make it work.

Real Myth 9: A company is considered PCI compliant even after the expiry of certification, due to 90 days grace period from the council

I know what you are thinking. You are thinking, this myth is way too specific and it sounds as if this is a real life scenario that actually occurred. You are right. Because this was exactly what we faced not long ago. You see, we had a financial institution we were chasing for a PCI renewal. They outsourced their datacenter to another company (which is common), so therefore, in accordance to PCI requirements, that datacenter needs to be included in their PCI-DSS, either demonstrating their (DC’s) own AoC or to participate with my client’s. The DC chose the former, to show their own AoC. So far, it’s ok. But then, our client’s PCI-DSS expiry is on February. The DC over the years have always managed to renew their own PCI-DSS cert on time (about a month or so before our client) so we have always had a compliant report from them (the DC). Until recently.

So while checking requirement 9 Physical Security, we noted that the AoC provided to us from the DC had already expired about two months back, and our client’s expiry is in about a month’s time. So we rightly requested them to provide us an updated AoC. Instead we received a response stating that even though their AoC has ‘expired’, as per PCI, their compliance status is still valid for 90 days (3 months) grace period, and they will be conducting an audit sometime within these 3 months.

Oh-kay.

Firstly, just to be clear, PCI-DSS doesn’t give any 90 days grace period or what not. As in, it’s not part of the standard, or part of the PCI Council’s policy. Any grace period is given by the card brands to those under their contract and that even if they choose to do so. It’s those sort of thing that is like a ‘privilege not a right’. However, since this data center has NOTHING to do with the card brands (they are directly providing service to an Financial institution, and not connected to the card brands), how did the card brands provide this 90 day grace period to them? It’s definitely not the QSA who can provide any grace period. So where did it come from?

Secondly – a grace period is a grace period against something that you did not meet. In this case, it’s the PCI standard that you did not meet, i.e you are NON COMPLIANT with an expired AoC. That’s why it’s called a grace period. Whatever the penalty or action is, that 90 days is the ‘grace period’ you have before the hammer of justice falls. The fact is, the deadline has already been missed. You are now under ‘grace’. The meaning of grace is ‘undeserved favor’ (evangelicals like to use this terminology, but I digress). You don’t deserve it, because you are non-compliant and you have missed the deadline. But the card brand is giving you a favor before they implement PCI-DSS penalties or fees on you. 90 days, get your act together, else boom.

Now, obviously, if this data center gives this response as a justification of not producing a compliant AoC, how can our QSA accept that as a proof of compliance? Unless you are saying, our client should also be delayed 3 months from their compliance date just because this data center decides to take advantage of this so called ‘grace period’? You see where the problem is. The grace period isn’t stating the company is still compliant to PCI (they are no longer compliant without a valid AoC) – it’s stating, that’s the period of time the card brands will give before they smack you with penalties according to their contract.

Real Myth 10: If the company is an ISMS certified company, they have already complied to 90% of PCI-DSS

We get this a lot. And again, it’s very understandable why people think of such. And to be honest, there is some truth here. Being ISMS certified DOES help you become PCI compliant. And vice versa. They are both IT security standards/guidelines and seen as a distant cousin of each other. However, we do get potential customers arguing to us that because they are already ISMS certified, then we should only charge them 10% of what we normally charge for PCI.

That’s a head scratcher for sure. It’s like if I had a driving license from Malaysia and I apply to get my license in Australia and I demand the Australian government (or whoever runs their driving license department) to give me the Australian driving license for 10% of the fee. How? The audit for PCI needs to be done regardless of whether you are ISMS or not. Where you will likely save up money is in the remediation stage where you may end up implementing less controls. But the audit has to be done in the same manner as any other audit.

Additionally, while both ISMS and PCI deals with the same subject – Information Security – the philosophy is different. ISMS hinges on the Statement of Applicability and the risk assessment process. That’s key. In fact many of the controls and their implementation will be based on the risk process – and furthermore, how the ISMS can be improved in every iteration. It is a ‘system’ after all.

PCI is different. While there is a ‘token’ risk assessment in there, you need to understand that PCI-DSS is a risk-based standard…only, not your risks. But the card brand’s. It’s the result of a risk assessment, which has already been done by the card brands. That’s why they decide to impose these standards – logical security, audit and monitoring, secure software development etc on you. There’s not much disaster recovery or backup requirements because that’s a business risk. It’s not a risk to credit card confidentiality. So is a risk assessment still useful? I think it still is. A whole article can be written on how useful or superfluous one may find the risk assessment requirement is for PCI, but let’s leave it for another day.

Summary

Even from the start of writing this series till now, I’ve been beset with new enquiries and PCI interpretations that has left me flabbergasted. Some of these interpretations are not unlike theories of the flat world, where it can be easily explained. Others have found little tiny crevices in the standard itself that I myself after reading the standard a dozen times over would never think of. So, to say, we are still learning a lot about PCI-DSS and how different entities see it and interpret it, so these myths may not age well. There could be a whole new list of 10 Real Myths in about a year or so. Till then, drop us any enquiries at pcidss@pkfmalaysia.com and we will do our best to guide you through PCI-DSS and the infinity that lies beyond.

PCI and the art of scoping

A lot of people we have met had told us this: “Since we are ISO27001, PCI should be a piece of cake, right?”

The context of this is because ISO27001 and PCI are often seen as distant cousins. They are both very relevant in our country and region (unlike other compliance like HIPAA), both deal with information security, and the overlaps between the Annex A controls of ISMS and PCI are evident. Therefore, the natural conclusion is ISO27001 is either a superset or a subset of PCI-DSS.

The problem with this assumption begins right at the start. In ISO, the scoping is largely determined by information that matters to your business. Before the iteration of 2013, scoping was generally done in a cowboy sort of manner. We met a company who had tons of sensitive information and told us they were ISO27001 compliant – and their scope was the security of their printing documents. Yes. How they literally secured the hard copies of the printouts. That was their scope statement.

Now 2013 version of ISO27001 had tried to stem these shenanigans by introducing interfaces and dependencies. Basically now the scope needs to cover information that are deemed important enough to protect from business perspective. This would cover the products and services relevant to the context of the organisation. Overall, scope determination of the ISMS can be a prolonged matter if you have a large organisation, and is often subjected to the business side of the organisation.

PCI scope?

It’s determined by the information that matters to the payment card brands, not your organisation. Credit Card Information. Primary Account Number. That’s it.

If you store, transmit and process PAN, PCI applies. If you don’t do any of these, and you do not influence any transactions in the payment card flow, then PCI doesn’t apply.

Often, people express utter shock that PCI doesn’t have any business continuity requirements. In terms of the holy trinity of information security – Confidentiality, Integrity and Availability (CIA), PCI primarily focuses on Confidentiality. Integrity is only focused in terms of its relation to confidentiality (Integrity of logs, integrity of system changes, system files etc), and there is no concern on Availability. Which makes sense. Between you closing down your business for one week versus you losing credit card information of your customers, the latter is viewed as more critical to the payment brands than the former. Although from a business perspective, a loss of business for a merchant is a loss of business for the entire data flow, upstream or downstream, so PCI not really caring about your RTO or RPO may be counter productive – but that’s an argument for another day.

At the end PCI scope boils down to you storing, transmitting or processing card holder data (CHD). Even if you don’t do any of these 3, you might still be in scope if you influence the security – an example would be those SAQ A e-commerce merchants that redirects requests to another PCI service provider. Even though they don’t deal with the CHD, they influence the transaction through their redirects, therefore, some parts of the requirements need to be met.

So – before we start our PCI journey, it is  very important to know what is the scope that is covered in your PCI environment. We may not want to take the whole environment as IN SCOPE – for cost, quality and timeline purposes. Our normal practice here is to reduce the scope as much as we can, a process we consultants term as “Scope Optimisation” simply because it sounds grand. I mean it sounds better than “Reduce your scope” which generally is interpreted to “reduce your price”.

In general, there are six things that we have to compile before we truly initiate the PCI journey.

a) Location and Address of the PCI scope. This is simple enough. Usually your data center is in scope. Depending on whether you store, transmit or process card data in your other offices, those come in scope as well. A question here would be – what about HQ, where our administrators access the PCI systems in DC, via a VPN connection? Ah. The secret sauce of putting things out of scope in a remote location where there is no storage, transmission or processing (lets just shorten these to STP from here on) of card data but there is access from an admin systems – multi-factor authentication. As long as this is in place, while the admin system is in scope, the location itself is then put out of scope. So you can connect from Starbucks, your home, or Timbuktu, and you would not have these locations dragged into your precious scope.

b) Applications that STP CHD. Store, transmit or process card holder data. Many queries have been like – oh, do we need to use PA-DSS applications? Well, if you do use PA-DSS certified applications, it would be very useful. However, even if you do not, you can still access that application as part of your scope under Requirement 6. In fact, some applications may not even be able to be PA-DSS for many reasons, such as it not being part of the authorisation or settlement flow but still storing card data. A custom CRM for example would be one that cannot be PA-DSS but still in scope for card data application. OTC (off the counter) products that store card data are still in scope, however, they need to be assessed properly to determine if there are any security issues that may influence the confidentiality of card information.

c) Network Diagram – an updated network diagram is a must. And a network diagram needs to be detailed enough to be able to differentiate the PCI and non-PCI zones. The important thing we need to take note on the network diagram is the proper demarcation of PCI zones, so we know what are:

  1. Card data environment in scope (CDE-IN-SCOPE) – ZONE A
    1. Any system that store or process or transmit CHD
    2. For example, application server, Database server
  2. Non-Card data environment in scope (NON-CDE-INSCOPE) – ZONE B
    1. Any system that require to communicate with CHD
    2. For example, patch server, anti-virus server
  3. Out of Scope – ZONE C
    1. System not related and has no communication with CHD – but might communicate with NON CDE IN SCOPE.
    2. For example, CCTV server in your office environment

d) Asset List for PCI – the asset list is critical because this relates directly to the effort and remediation costs of your PCI program. There is a huge difference in doing pentest for 200 systems versus 20 systems. So in this case, we don’t care about your assets considered not in scope, we want to know the assets in CDE and in NON-CDE in scope (Zone A and B).

e) Public IP addresses – this is needed because of ASV scans required. ASV scans are security scans done by the ASV (Approved Scan Vendors) of PCI. You can’t do it yourself, you need to get an ASV to do this for you.

f) Data Flow Diagram – This shows the card data flow in your organisation. Basically every channel where credit card enters into your environment, stored and process and exits. This details the lifecycle of CHD in your organisation whether it ends up being stored in a database for seven years, or passed out to another service provider. It’s essential to understand this – and if you have multiple channels where card is being entered (e.g e-commerce, POS, MOTO, Call Centers, KIOSKS etc) you need to document each of these from start to end.

So there you have it. PCI scoping at your fingertips. Drop us an email at pcidss@pkfmalaysia.com and we can have a free session with your organisation on what could be your possible scope, which likely may not be just your printouts coming out of your printer!

The Long Road of PCI Recertification

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We have been in PCI-DSS for six years.

When we began back in 2010, we were tasked by one of our offshore customers in Brunei to get them “PCI” certified. Honestly, back then, early 2010, we were mainly doing IT audits under COBIT, a lot of penetration testing, some IT forensics and bogged down with piles of ISO27001 ISMS opportunities.Back then PCI was more known as Peripheral Card Interconnect, which are those add-on cards that you slot into your motherboard back in the days when you wanted to extend your network interfaces, graphics accelerators etc. I used to build computers in those dodgy computer shops back in the days, so I kind know that very well.

Fast forward six years, and now we are getting more and more queries for PCI-DSS. So much so that we have dedicated an entire team from our company to work only on PCI-DSS projects.

In earlier years, we brought our PCI clients through their first year certification, and many of them are now going through their 2nd, 3rd year recertification etc.You would think that most companies will find re-certification easy compared to the first time certification.

Don’t be fooled.

The thing about PCI is, during the re-certification, there is a lot more expectations on your organisation for compliance. An example – PCI requires logs to be retained 3 months online, 12 months offline. It also requires daily log reviews, as well as quarterly internal and external vulnerability scans.

Now for the first time certification, some of these requirements get a free pass: meaning, if our client had just installed a SIEM and only has 2 – 3 months logging set up, we verify those controls and based on those controls, we can pass their PCI. We don’t need to wait for 12 months to get the offline requirement passed. Likewise, if our client provides us with one internal and external scan, we can pass them for first time, we do not need a 4 quarterly scan before we sign off on the initial AoC.

However – once the re-certification arrives, these become MUSTs. Some of our clients want to undertake internal scans themselves and missed one quarter and expects us to still pass them. Or they have a SIEM, but no action done on daily reviews, or their SIEM was not set up properly and no logs were sent there. They get upset when we say we can’t pass them on those basis because their response was “We did this last year!”

Also, evidences.

Whenever we conduct our audits, we conduct it onsite. Onsite, the QSA will verify these controls if they are in place or not. On top of that, we require audit evidences. This is normal even out of PCI – in our governance audit or ITGC we often rely on audit artefacts (we call it), to supplement our opinion on whether certain controls are in place. In PCI, these evidences might come in forms of documents, policies, screenshots, configs etc – anything that can prove controls are in place, and effective, and accordingly used as per PCI requirements.

The onsite audit confirms these controls. The evidences supplement the QA process. Each QSA needs to go through a stringent QA (quality assurance) process internally, whereby, the QA requires supplementary evidences to prove why the QSA arrives to such and such an opinion. Therefore,  there is always that post-audit work of compiling audit evidences.

Some clients are of the opinion that the onsite audit should end the process and the auditor passes PCI then and there. Unfortunately it’s not so simple as there is a check and balance involved. An example is this: one of our clients recently added in a few out of scope devices into the CDE. During the onsite audit, we referred these and requested these systems removed or resettled in another segment. They said, OK, we will put it in another VLAN. So, if they do that, is that ok? We said OK.

Fast forward to the post-audit work, we asked “Hey, have you done your VLAN yet?”

“Yes, we have. Can you pass us?”

“OK, can you give a screenshot of the new configuration in your firewall or switch to prove that you have done this action?”

“WHAT??! Why??!”

You see – as auditors, we simply cannot trust you for your word. It’s not personal. It’s not that because we find you are a shifty trader looking to spin some yarn and fleece us of our money. It’s simply because it’s part of our job. Evidences provide us with some measure of assurance that these controls are done correctly and in place. It’s not that we question your integrity. It’s strange that even at this stage, many people find this difficult to accept, and we have gone through many, many strange situations whereby I have faced a red-faced, yelling executive thinking that I am personally insulting him and his family name by not trusting what he is saying.

Audit evidences. It’s part of PCI.

There are of course some exceptions, such as certain private and confidential documents or config that cannot be shared – even in that case, we generally ask these information to be anonymized, but evidences to be submitted all the same: for instance, evidence of VLAN config, you can screenshot the config, and remove elements deemed sensitive (IP Address, versions, other information etc).

In summary – the second year onwards, this is where the real PCI battles begin. Your recertification efforts will be a whole lot more than the first time, so get started early. We will be posting more articles on tips and actions that will make your PCI certification successful.

In the meantime, drop us a note at pcidss@pkfmalaysia.com and we will attend to any queries you have.

PCI DSS and the Problem of Scoping

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I recall in an actual case a few years back when I received a call from a company requesting us to do a certification for PCI for them. So I met them and drew out their PCI plan starting with a gap assessment, remediation and certification audit.

They said they have already done their own gap assessments internally by their ISMS guys. And they will be doing all their remediation on their own and they just needed me to quote for certification audit because “PCI is forcing us to be certified by a third party, which we believe we can do it better than you can”.

There was nothing much to talk to them about, but I did mention that if we find major NC (non compliances, in ISMS speak), we would then use that ‘certification audit’ as our own gap assessment and that we might be required to come back again to verify.

The company truly believed that PCI was a subset of ISMS and they handled it as such.

So we came in for the certification and found out that their entire scope was completely messed up. For instance, there was another out of scope network and systems connecting into their CDE for monitoring. Because card data wasn’t passing through, they marked it as out of scope. Unfortunately, PCI doesn’t see it that way. This would be considered an Non CDE In Scope, and systems within this network will need to be secured as well, and hardened as per PCI. The logic is that if these systems are compromised, there is a path into the CDE that can be exploited.

They made a huge fuss on this, claiming that they are willing to absorb the risk and that their management signs off on the risk assessment.

ISMS is a best practice/guideline at best – it’s a great marker for security, but PCI is a standard. If you can’t meet it, then you don’t meet it. Of course, there are ways around this particular issue, but they insisted we passed them simply because their management accepted the risk.

Here’s another idea: PCI-DSS generally doesn’t really care about your business. It’s not about you. It’s about card data. Visa/Mastercard and the Jedi PCI council are not concerned about your business – they are concerned about the confidentiality and integrity of card data. That’s why you will not find any BCM or DRP requirement in PCI. RTO and RPO? Pfft. They don’t care. Your business can go down for 10 weeks but as long as card data is safe, it’s good.

And that’s why, scoping is HUGELY important. Many people might think that a gap assessment is a waste of time. It is, if it’s done incorrectly. I recently witnessed a ‘gap assessment’ report that was a complete mess. It just detailed the PCI twelve requirements and in each requirement gave an overview of the company’s controls and what they should be doing: ripped off almost verbatim from the actual standard itself. That can be downloaded for free.

A gap assessment needs to bring you from one place to another and needs to provide these:

a) A clear understanding of your scope, including a writeup on your network, and processes that have been assessed. It should also be clear what is out of scope. This initial scope usually is not set in stone as remediation would sometimes change what is in scope and what is not in scope. But at least you have something concrete to start with.

b) If possible, an asset register. For PCI. If this is not possible (for many reasons, e.g they have not purchase some assets required for a control), then the asset inventory needs to be prioritised a quickly as possible to see what is scoped and not. Asset should be clear on: Public ips, internal devices, servers, network devices, people involved, desktops, databases etc.

c) Network in scope and out of scope. This is key as companies are required to identify segments scoped out, and do segmentation testing. Also, CDE is clearly marked, NON-CDE IN SCOPE (we call it NCIS) must also be identified. Systems in NCIS could be monitoring system, SIEM, AD etc. Any system that connects to the CDE, but does not store, transmit or process credit card data are considered NCIS. NCIS must be scoped for testing, quarterly scans, hardening and such.

d) Clear roadmap for remediation and recommendations to proceed, specific to the organisation. These ‘gaps’ should all have a corresponding solution(s).

If the gap assessment doesn’t give you any of these, then it’s pretty useless. If it doesn’t move you forward or provide you with the information to move forward, it’s not a gap assessment. It’s an expensive training session.

So back to the first example of a customer. It wasn’t possible for us to certify them no matter how they argued, because simply they were not compliant (there were also many issues that they did not comply, for instance storage of card data in text files and sending via emails).

As a lesson – don’t neglect the proper scoping. It’s hard work, but as I always say: Start wrongly, do wrongly, finish wrongly. And that’s 6 – 8 months down the drain, with thousands of ringgit gone in investing, and job on the line. The second example is pertinent also. There is always a chance to OVERSCOPE as there is to UNDERscope.

An overscoping example would be to purchase all sort of snazzy security systems worth thousands of ringgit only to find that these were not needed, or that current controls were sufficient. It’s nice to have – but most of our customers, no matter how big they are, always have a trigger on the budget and cost optimisation is the topmost in their priority.

If you want us to help you in your PCI-DSS scoping, drop us a note at avantedge@pkfmalaysia.com and we can get you started with the initial understanding straight away!

The Myths of the Top 10 Myths of PCI-DSS

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A while back, the PCI council published a good article called the Ten Common Myths of PCI-DSS, to basically debunk a few conclusions people (or so they think) might have on PCI-DSS.

After wading deep into this standard for the past 6 years, I am taking a look again at these myths and I am like, Wait a minute, this isn’t exactly correct.

Myth 1 – One vendor and product will make us compliant

This myth is hard to beat. It’s obvious that one vendor and one product doesn’t make anybody compliant since PCI-DSS is so much more than a product or an implementation. It’s the practice of security within an organisation itself. But wait. Not all PCI projects are created equal, and here’s where we call ‘scope reduction’ comes into play. It is possible that a product can significantly reduce scope so much so that it’s almost easy to become compliant. For instance, tokenization. This is a solution created to remove the need of dealing and storing actual card data in a merchant environment. Instead a token is used and is mapped in the token vault provided by a service provider. Hence, the merchant does not have the key or means to decrypt. Of course, they still handle the first time card data is transmitted through, but it removes the need of the merchant to completely fill the dreaded SAQ D-MER as they no longer need to store card data. Or P2PE for instance. When it started, the solution was to provide a point to point encryption so that merchants need not have the means to manage the keys or decrypt the data. Of course, P2PE bombed and they had to revise the standard to make it more realistic.

Myth 2 – Outsourcing card processing makes us compliant

Again – if you outsource card processing, it might not immediately make you compliant but it sure as heck make it a lot easier to be compliant! With the new revisions of SAQ, we have the nicely flavoured SAQ-A and SAQ A-EP for ecommerce merchants to deal with, to avoid the death knell of SAQ D-MER. There are like 9 flavours of SAQ (self assessment questionaire if you are wondering), and merchants might differ in their journey of PCI depending on their business. Outsourcing to a PCI compliant card processor or payment gateway is a great way to reduce your scope. So while this myth is correct, outsourcing is still a great strategy if payment processing is not your core business.

Myth 3 – PCI compliance is an IT project

Everyone will nod their head in the board room and steering com and agree to this one sagely. But from experience, I will tell you, whether it’s business or IT project – IT guys will be significantly involved in it. If you think you can breeze through this sucker the way you championed through ISO27001, you are in for a little surprise. A large part of the 12 requirements deal with technical requirements, from firewall configuration to antivirus to logical access controls. Logging and key management are significant challenges we find, and an entire requirement 6 deals with patch management and secure coding practices. So, if you are not familiar with terms like OWASP, KEK, DEK, WSUS, TACACS/ACS/LDAP, XSS, CSRF,CVE and all these, it’s time to get cracking. Having done both ISO27001 and PCI, we can say the ISO is more of a best practice/guideline on security while PCI is a standard. It’s either you do or do not. There is no try.

Myth 4 – PCI will make us secure

I know what this myth is trying to say, but technically, if you are practicing PCI, you are a heck lot more secure than someone that’s not. Besides, being ‘secure’ isn’t a final state to be – it’s not possible, but rather it should be a constant practice of a hundred different activities to contribute to ‘being secure’. It’s like when people talk about ‘enlightenment’ or ‘world peace’ – it’s not actually achievable – and even if it is – it’s not sustainable. So yes, PCI will make you secure , relative to the company that has their server under a marketing director’s desk and the password “PASSWORD”.

Myth 5 – PCI is unreasonable; it requires too much

Obviously, PCI Council wants you to think this (again, they are saying these are myths, so whatever you read, PCI Council is asking you to think opposite). They are saying, PCI is reasonable, it doesn’t require much.

I disagree.

It requires a lot.

I mean, OK, if you say SAQ A or A-EP, fine, agreed, it’s a breeze.  But if you are talking about SAQ D or a full cert?

Unless you have unlimited resources, money, time or already practicing some Level 5 Maturity of security, then you need to really look into managing PCI. Most of our clients aren’t in that state, so when you talk to them about the amount of work needed? Oh boy.

Let’s say they have 40 devices in scope. Multiple applications, running on multiple servers. Several layers of firewalls. Firewall rules need to be clean. Sounds easier than it is. The amount of legacy rules we see in some clients would make you think that firewall has been around since the internet was invented. Server upgrades due to EOL. Network changes because the database is accessing the internet directly. Applications not patched. Devices not updated. Logging not centralised. No correlation of logs or event management. No incident management. No central management of passwords and users. Applications developed eons ago and developers have since left the company with the only document being a note saying, “Goodbye and thanks for all the fish!”. You get the drift.

Myth 5 and Myth 10 (PCI is too hard) is the same. When you put the word “TOO” in there, its brings in relativity. What is “TOO” to some companies? When you have a single administrator running the whole thing and he is dividing his time between this and a thousand other things, “TOO” might be the key phrase there. So, I won’t say it’s not possible for a full certification – it obviously is, since we have certified a number – but what we don’t want is our clients walking into PCI with expectations of breezing through and then get slammed like a deer in headlights. It will take effort. It will take resources. It will take money and it will take time. Yeah, time. Around 3 – 4 months if you are lucky for a full certifications. I often get a stunned look of disbelief and a general retort that goes like: “<insert invectives here>, I thought it would only take 2 – 4 weeks, man.”

Look – PCI is really useful and it’s not the intention to discourage people from going for it – but it would be great to be better informed so that expectations can be synced to reality. In the next article, we will cover the remaining myths of PCI.

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