Tag: IT security

PCI-DSS Full Disk Encryption Part 2

In our previous article we wrote on how Bitlocker can possibly be used as a full disk encryption solution for PCI-DSS.

One of the key things is for the following statement to be complied to:

If disk encryption is used (rather than file- or column-level database encryption), logical access must be managed separately and independently of native operating system authentication and access control mechanisms (for example, by not using local user account databases or general network login credentials). Decryption keys must not be associated with user accounts.

By enabling TPM itself doesn’t guarantee that the native authentication is separated from the logical access to the encrypted file system.

The below basically enables TPM with PIN to ensure that there is an additional logical access that is required to comply to PCI-DSS.

So overall, this means that Bitlocker needs an extra authentication when the server restarts. As the policy states, either a passphrase or USB will be required for the startup, and from PCI perspective, this addresses the separate authentication requirement.

Of course the major discussion here is what is compliance and what is practical security?

Because when was the last time you actually restarted your server? The fact is that full disk encryption is only as useful as it is to protect data on the disk when the system is not running. When the server is running, access to the disk remains open and therefore, we see unprotected PANs with their pants dropped (so to speak).

We are not saying that bitlocker cannot comply to 3.4.1 of PCI. We are saying probably PCI might be better off relooking at this 3.4.1 and clarify the ‘spirit’ of this requirement. At the end, we are concerned with loss of PAN. We are concerned with the fact that files may be taken away, siphoned away through a variety of means – either through the network, or USB, or photos on your phone etc.

The problem with Full Disk Encryption is that even if we do have separate authentication to boot up into the server, once it’s booted and once authenticated separately, the full disk encryption no longer does the job of ‘rendering PANs unreadable where they are stored’. The argument thus comes about that once that occurs, then whoever is reading those PANs are authorised users already with business requirements to view those PANs.

In our opinion, there needs to be much more security surrounding these servers with PANs that use full disk encryption. Access must be limited again to only those with business justification, and not be used for multiple purposes and especially not for non-PCI usage. Logical access, hardening, logging and monitoring obviously needs to be in place. Protection of the PIN must be in place, and changes of PINs based on PCI-DSS expiry policies.

The comfort level of FDE vs say, file encryption or even folder encryption is much less. Whether it meets 3.4.1, if done properly, it clearly does. But is it truly secure? Therein lies that discrepancy between compliance and security. It ticks the checkbox (for now, unless PCI alters it in 4.0), but from a security standpoint, there is a lot of risk surrounding it.

If you use FDE, don’t expect your QSA to just take it lying down. Most likely further queries will be made and some may deem it even insufficient in itself to address the risks of PAN being compromised and may request additional controls on top of it.

If you have further queries on FDE or any compliance programs like PCI, ISO etc, drop us an email at avantedge@pkfmalaysia.com and we will attend to it immediately!

PCI-DSS: The Art of Getting By

The Art of Getting By is a movie that wasn’t very good. I don’t recall much of it, except the title was appropriate for this article.

The general idea of PCI-DSS is that it’s easier to maintain the compliance than to first obtain it, and while there are nuggets of truth there, we would venture to turn that idea upside down: It’s much harder maintaining it that to obtain it. Maybe it’s like marriage, where after the wedding and honeymoon, the real work begins in ensuring you have 40-50 years left in the tank with your partner (depending on when you tie the knot of course, and in some cases, depending on how many kids you end up having. That’s added stress.). In some ways, it’s similar, and over 8 years of PCI experience had taught us that while we should always (again – ALWAYS) celebrate the success of first time compliance to PCI, we must not forget what lies ahead of us.

PCI Council realises this and in Appendix A3 of their PCI standard, lists out a few extra things for DESV (Designated Entities Supplemental Validation). It must be noted however, these are not automatically mandatory for PCI companies, but for companies designated by their card brands or acquirer based on risks and oftentimes, volume of transactions. If you are not required to go through DESV, don’t go searching for it.

DESV puts in a few extra components to the PCI standard. One of the requirements is to Implement a continuous PCI-DSS program in the organisation. What has been noted by the council is that while many companies do attain PCI-DSS, they treat the standard as an event they need to get by each year. This means companies, instead of practicing PCI in their daily work, seek to re-certify each year based on a series of checklist they need to do at that point in time. Which isn’t cool. But that’s how almost everyone approaches it. It’s like taking your semester exams in University. It’s not like in day to day living, we are thinking about the real value of x in a log2 equation or what are the prime numbers that are relevant to your life. We are just thinking about hanging out, cutting classes and kicking up dust. When the exams come, we mug, we eat ramen noodles for every single meal, we don’t go out, we don’t sleep and we generally try our darnest not to fail, and then the whole cycle of meaninglessness begins again. I don’t really recall much of my university days, as you can tell. And that’s how PCI is sometimes approached.

So how does one stay compliant, instead of just pass compliance?

Management Buy In

We hear this a lot from our management text books. Management Buy In. Unless we have a top down support and sponsor on compliance, PCI is going to be a drudgery faced every year. IT is going to be bombarded with all kinds of requests on top of their already busy day to day work. Most success comes if the business recognises the importance of PCI to their organisation. We have some rare instance where clients do PCI just “because they want to, and they want to look good”, but more often than not, those attempts fizzle out once they realise it’s a rabbit hole you can’t get out of. A cost benefit analysis is key here, and a business case needs to be built, because you are going to end up spending a lot in this compliance, and that spend should be backed up with sound revenue and business in the pipeline – directly generated because of your compliance.

Having a Compliance Team

You need a go-to guy, or a go-to group for this compliance. We have experience where PCI is dumped into an organisation and every week we are dealing with different people. We have one customer who named a project manager to lead the project and his appearance in our meetings is as rare as Yeti sightings. We sit in the meeting and we go, “Where’s so-and-so?”. Some wide eyed junior IT guy goes, “Oh he’s busy with another project, and I am asked to lead”. Anything we discuss, he just goes, “OK, I need to check with so-and-so and get back to you.” Without decision makers in the team, we end up going around in circles and before you know it, 6 months have passed and we are still on the same agenda. It’s like going 3 levels deep in an Inception dream. Get a team. You don’t need to bring in 20 people in the meeting where 18 people sit away from the table, typing furiously at their laptops as if they are writing the next War and Peace novel. 3 or 4 key guys: Person in charge, network and server team representatives, developer rep and if you have SOC/security team rep. Everyone should either be an influencer or a decision maker, and we are good to go.

Business As Usual

We call it BAU. Many have suggested PCI is asking ridiculous requirements which are too difficult to meet. In reality, PCI is basically asking for baselines. The very least organisations should be doing to secure themselves. Security needs to be practiced, and not just implemented as a checklist over a short period of time. For instance, the requirement for daily log monitoring. This is not something you can conjure up when the auditor comes and audit. If you are not practicing it, you are not practicing it. Or simple things like CCTV monitoring. We faced a client doing recertification and on a pre-audit check, we found their CCTV had not be recording for 8 months due to maintenance. I asked why was this not reported or checked, and they sheepishly told me they had no clue and they had never bothered to even check since they passed their cert. PCI requires a fair bit from organisations, for example:

Daily Monitoring of logs, and access to secure area, weekly checks on FIM logs

Monthly checks on critical patches

Quarterly – Wireless Scans, ASV, Internal Scans

Half Yearly – Firewall review, user deactivation

Annual – Pentest, application testing, Risk assessment, training, Inventory checks and review, policy review, service provider review, Incident response, segment checks etc

Those are just part of the listing. So unless you plan to have sleepless nights during the audit period, it’s best to get these done as part of your day to day. We need to note that in most cases, these should be practiced in any case, regardless of PCI or not!

Yes, a lot of these are easier said than done. We are aware teams are being pulled sixteen different directions and PCI is just one of it. It falls back to how critical this compliance is. To many, it’s required to continue their business as it is a contractual obligation. So it’s not just about getting by, although in some cases that might work – but for PCI, we would recommend to embed these practices as much as possible into your organisation, so that when audit season comes, you don’t end up overeating your Ramen noodles.

Get in touch with us through pcidss@pkfmalaysia.com for any enquiry on PCI-DSS!

The Single Point of Failure

As technology becomes more and more advanced, we’re seeing an amazing progress in the security field. Companies spend millions to keep the bad guys out. We have IPS/IDS, NACs, AVs, FWs, AAA, TACACS, ADS, IAM, SIEM and more acronyms than a typical teenager’s vocabulary. ┬áSecurity budgets consistently spans 10 – 15% of organisation budgets, and according to the greatest oracle of all, Gartner:

“While the global economic slowdown has been putting pressure on IT budgets, security is expected to remain a priority through 2016, according to Gartner, Inc. Worldwide spending on security is expected to rise to $60 billion in 2012, up 8.4 percent from $55 billion in 2011. Gartner expects this trajectory to continue, reaching $86 billion in 2016.”

So this year, we’re seeing an IT security spending of the GDP of Cuba. Yup, Cuba. Where Havana cigars come from and Che Guevara became famous. It sounds like a lot of money. And it will get higher. As long as more automation is done. As long as more technology is needed. As long as more day-to-day banking is needed. As long as human beings are lazier and want more things faster. Information Technology will continue to grow, and along with it, all the wonderfully, naughty activities that invariably accompany such growth.

While millions are spent on equipments, many of us neglect one of the most basic problem of all.

Passwords don’t work.

That’s because humans are invariably lazy. Or we would rather remember the phone number of that girl we met at the bar, or the pizza take out than to bother remembering our 12 letter, alpha numeric, lower case, upper case, special character password that must not resemble an english word or name, and must not be the same as the last 12 passwords you have, and recycled every month. And yeah, also can’t be your name, your family name, your dog’s name or the nickname you named your car. Or your bike. Or your computer, for us geeks.

It’s a broken feature. This article is both hilarious and scary. Like a korean horror movie.

Since biometric tech like fingerprint and face scanning is too expensive at the moment, passwords are still the defacto security problem many of us face. You can’t impose too complicated passwords on your users or your IT service desk will be flooded with “I forgot my password” tickets. Or you will have to constantly implement a “Reset you password” feature every day. But having no password policies is also asking for it. Users will tend to use password as password, which if you think about it, is absolutely genius if no one knows about it. It’s like doing the most stupidly obvious thing that your enemy would not believe that you’d be stupid enough to do it. Except now, it’s a known and acceptable stupidity, like lemmings falling off a cliff.

Password123, p@ssw0rd (or any other variants of that), password1, password2012 etc have all the same funky, useless theme: we are lazy creatures. The list has some interesting ones, like abc123 (who has never used that before?) and interestingly, Jesus, which is new. I mean, is that due to lots of IT users are christians, or that would be the first word that comes out of people’s lips when they think “Now what on earth is my password already???!”

Since passwords will never leave us for the near future, the best way to use a password is ┬ásimple, specific, and only you know about it. For instance, if you met your wife in Cicero’s on June 1986, your password could be c1cer0s1986_J. Or something. Craft out something that when you see that word, you can immediately associate it with a memory you have. Or if you paraglided down Mount Mutombo in Venuzuela with a guy called Hokey who then proceeded to almost kill you because you are a secret agent: Mut0mb0V3n_Hok3y_Di3! I don’t know. You get the idea.

So put away the normal passwords, and more importantly don’t ever, ever use yellow stick it notes on your cubicle, monitor, desk, pedestal, under your keyboard or under your chair. Please.

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