Lyal, all,
Sorry for the delay-- I had vacation.
Lyal Collins wrote:
I don't think it's a question of the PCI document being right or wrong, but
of compliance to a set of domumented requirements in order to either stay in
business or minimise financial impact on a company if a security breach
involving credit cards occurs.
This is indeed a problem where compliance is seen as protection. The
two are very often not the same. Why accept the PCI document as one
that minimizes financial impact, privacy breaches, etc. if the premise
only scratches the surface of the definition of protection? We cannot
simply accept that products, blacklists, and the products that love them
are to be regulations. Compliance should be simply the do's and don'ts
of protection and loss controls with metrics to assure compliance.
Remember that best practices are not best for all. The protection
requirements should be documented but not the process of achieving them.
PCI requires, among 190+ other things, vuln scanning of all internet facing
systems, and those internal systems that process cardholder data, not the
entire internal network. PCI also requires an annual pen-test, to attempt
to exploit scanning-discovered vulnerabilities. Of course you may choose
to scan the rest of the entire network as part of enterprise security
management.
Pen tests are another thing that are also poor security tests.
Requiring a pen test is barely better than requiring a vulnerability
scan of systems that hold cardholder data. But maybe I don't understand
what you mean by pen test. To me it's a test for exploiting weaknesses
in a network to raise privileges and meet a pre-assigned goal (such as
card member data).
In that case a pen test is big mistake. A black box pen test can only
ever be favorable to the client as opposed to one where the tester has
more information about the network, the systems, the processes, and the
alert/alarm profile. The latter is more beneficial to the card holders
and the card issuers because it would mean something about testing
protection and loss controls and not just the tester's skills.
Sure PCI is about compliance but takes the wrong approach to be about
protection and loss controls. For example, just asking for a
third-party every year is such a huge generalization because if you
consider the speed of progress, then shouldn't sites with more
interactions, a greater scope, need more frequent audits than smaller
ones? If this was based on a metric, you could assure audits were done
whenever the metric reached an unsavory number.
I know this document came out to improve things but it's still far from
that goal.
Sincerely,
-pete.
