Aug 10 2009

Managing Risks and NIST 800-53

Category: Security Risk Assessment — DISC @ 5:48 pm

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FISMA Certification & Accreditation Handbook

The organizations need to establish security program to manage their day to day risks. Before selecting the controls from standards such as (NIST 800-53 or ISO 27002), organizations need to have complete inventory of the assets involved in the scope. Assets involved in the scope would require a comprehensive risk assessment to determine the sensitivity/criticality of these assets. Depending on the categorization of these assets will determine an appropriate control from standard to mitigate relevant risk. In some cases supplemental controls may be required.

Management of risks involves the risks to the organization with the operation of an information system or information security management system. Risk management is an effective frame work for selecting appropriate security controls for an information system and assist in selecting of appropriate security controls to protect assets.

Both ISO and NIST standards follow the similar path in control selections. NIST 800-53 has 163 high level controls and 154 medium level controls which have around 95% mapping with ISO 27002 which has 133 controls. While NIST SP 800-53 is required for federal (unclassified) information system, NIST encourages its use in commercial space. Commercial organizations can utilize the NIST standard to create their security program, which will provide a road map to their security strategy and assist in making informed decisions for securing their information assets.

The management of day to day risks is a key element in an organizationā€™s information security program and both NIST and ISO provide an effective framework for selecting and managing the appropriate security controls for information system. ISO utilize PDCA (Plan, Do Check, and Act) Deming model for selecting the appropriate security controls and managing its information security management system. NIST on the other hand utilize the similar framework for selecting and managing appropriate controls for information system and is called risk management framework security life cycle. Copy of the NIST risk management framework security life cycle is available to see an eerie resemblance with PDCA model.

nist_rmf1

Around 80% of critical infrastructure resides in private sectors which required to be protected by various regulations. Both NIST and ISO can be utilized to protect assets, however in some cases one standard might fit better in your environment then the other or perhaps you are able to manage one standard better then the other. Both standards required their information system to be audited or reviewed by authorized organizations to achieve apporpriate certifications.

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Tags: iso 27001, iso 27002, NIST 800-53, PDCA, Risk management

May 06 2009

Rise of cybercrime and management responsibility

Category: Information Security,Information Warfare — DISC @ 5:08 pm

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According to SF Chronicle article by Deborah Gage (May 8, 2009, c2) consumer reports magazineā€™s annual ā€œState of the Netā€ survey finds that cybercrimes has held steady since 2004, with one out of five consumers becoming victims in last two years at a cost to economy of $8 billion. Consumer report can be found on at www.consumerreports.org

Uncertain economic time brings new threats and scams and most of the security experts agree that thereā€™s a possibility of increase in cybercrime for this year. Survey also found that around 1.7 million people were victims of identity theft and 1.2 million had replaced their computers because of infected software.

First why all the signs are showing uptick in cybercrimes and second what are we going to do about it.

Management should start considering security as total cost of ownership instead of wasting time on what is ROI of information security. If there is a security breach, somebody in the management should be held accountable not an IT or security personnel. Management will keep demonstrating lax attitude toward data protection and security in general unless there are serious consequences like spending time in jail for lack of security controls (basic due diligence) and not taking appropriate actions for the risks that posed a significant threat to the organization.

PCI, HIPAA and SOX compliance are a good start in a right direction for management to take information security into consideration, but these compliance initiatives donā€™t address the security of a whole organization. They address security risks of a business unit in an organization. If management is really serious about security then ISO 27002 code of practice is one of the option which should be considered to address the security of the whole organization and ultimately organization should achieve ISO 27001 certification which will build a comprehensive information security management system to manage ongoing risks.

[TABLE=2]

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Tags: Information Security, International Organization for Standardization, isms, iso 27001, iso 27002, Operating system, Policy, Security

Feb 12 2009

SB1386 and ISO27002

Category: ISO 27k — DISC @ 7:08 pm

In April 20007, California state IT council adopted the information security program guide which help organizations to comply with SB 1386. The council advised the use of information security standard ISO 27002 framework to comply and meet the needs of SB 1386.

[Table = 13]

Which businesses are affected by SB 1386 law?
o If you have a business in California
o Outsourcing company who does business with a company in California or have customers in California
o Data centers outside of California which store information of California residents

sb1386

Toolkits are designed to help organizations who need to comply with a law like SB 1386. SB 1386 and ISO 27002 implementation toolkit assist ISO 27002 compliance. Also help organizations who are interested in certification to lay in the ground work for (ISO 27001) certification that would demonstrate the conformance with world class information security management systems.


The Comprehensive SB1386 Implementation toolkit comprises of:
1. The SB 1386 Documentation Toolkit: a download with nearly 400 of densely packed pages of fit-for-purpose policies and procedures ensuring full compliance with SB 1386.
2. International IT Governance: An Executive Guide to ISO 17799/ISO 27001 (Soft Cover) This is the US version of the long established world leading manual on designing and implementing an Information Security Management System (ISMS) in line with the best practice guidance of ISO27001/ISO17799.
3. vsRiskā„¢- the Definitive ISO 27001: 2005-Compliant Information Security Risk Assessment Tool which in summary:
o automates and delivers an ISO/IEC 27001-compliant risk assessment
o Uniquely, can assess confidentiality, integrity & availability for each of business, legal and contractual aspects of information assets ā€“ as required by ISO 27001
o Comprehensive best-practice alignment
o Supports ISO 27001
o Supports ISO 27002 (ISO/IEC 17799)
o Conforms to ISO/IEC 27005
o Conforms to NIST SP 800-30
o The wizard-based approach simplifies and accelerates the risk assessment process;
o Integrated, regularly updated, BS7799-3 compliant threat and vulnerability databases.
4. Plus an electronic copy of the Information Security Standard ISO/IEC 27002: (formerly ISO 17799).

Buy The SB-1386 & ISO27002 Implementation Toolkit NOW!

ISO assessment is a great first step towards ISO 27002 compliance and toward the final goal of ISO 27001 certification audit or for that matter any compliance audit.

ISO 27002 Framework for Today’s Security Challenges
httpv://www.youtube.com/watch?v=yRFMfiLbNj8

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Tags: Information Security, Information Security Management System, International Organization for Standardization, iso 27001, iso 27002, iso 27005, iso assessment, National Institute of Standards and Technology, sb 1386

Jan 30 2009

ISO 27k and CMMI

Category: Information Security,ISO 27k — DISC @ 2:00 am

To become a successful business in todayā€™s market, optimized information security controls may be the panacea for unmet security needs. One way to achieve optimized information security control is to perform ISO assessmentĀ and assess the organization security posture based on ISO 27002 code of practice and map each control with Capability Maturity Model Integration (CMMI) to find out the current CMMI level for each control. information The goal is to address the organization security needs as a whole, and assess how different departments and business functions are addressing the current business security requirements. The CMMI has five levels and evaluate security controls based on levels, not on specific objectives. Each level provides the basis for the next level where it is not possible to get to the next level without complying with previous level. ISO 27002 is a comprehensive framework which can be utilized to obtain the baseline upon which to build each level. For each control in ISO 27002, maturity levels are defined using maturity definition found in CMMI. In the assessment report maturity level of each control of ISO 27002 standard can be evaluated. Utilizing the color coded scheme provided by CMMI model, create a one page ISO control summary for executives which will not only help them to understand the current security posture but also can be instrumental for measuring progress and resource allocation.

The scope of the ISO27k standards includes various aspects of IT. The introduction to ISO 27002 states clearly: ā€œInformation can exist in many forms. It can be printed or written on paper, stored electronically, transmitted by post of using electronic means, shown on films, or spoken in conversation. Whatever form information takes, or means by which it is shared or stored, it should always be appropriately protected.ā€

Benefits of ISO 27k framework:
o Framework addresses the security issues for the whole organization and limit data breaches
o Address compliance with various regulations like (SOX, HIPAA, and PCI) without creating silos.
o Reduce total cost of security by decreasing total number of controls required
o Perception of your business that you are serious about information security not just compliance
o Enhance partners and vendors confidence to do business with your organization
o Future deciding factor for national and especially international partners for more business
o Internationally recognized standard which addresses security awareness for the whole organization

isotocmmi

Assessment will give an organization a high level view of their current security posture and provide a road map for security strategy in a sense what needs to be addressed first utilizing risk based approach. This is also a good start if your organization is interested in the Information Security Management System (ISMS) or ISO 27001 certification. ISO 27001 is the standard for the certification which includes the set of requirements for ISMS. Justifiable scoping is the key to a quick and successful certification; organization may adjust their scope in a re-certification attempt. Perhaps in the first attempt you may need to include just a web portal in your scope and the entire infrastructure behind supporting that portal. Once the ISMS project scope is determined, here are some steps you can follow to prepare for ISO 27001 auditors.

1. Based on your scope, create an asset list
2. Find out asset threats and vulnerabilities and classify the asset based on CIA scale
3. Come up with risk matrix based on impact and likelihood of the risk
4. Create priorities based on impact and likelihood of the risk
5. Based on priorities, implement appropriate controls for risks which needs to be addressed
6. Do the risk assessment again, PDCA improve ISMS

ā€œISO27001 is a structured, technology-neutral, vendor-agnostic specification and code of practice for information security management in organizations of all sizes that should be adopted as part of an organization’s overall risk management strategy.ā€

This should give you a jump start to certification. You have already started the process of certification because most of the documentations in the risk assessment will become part of certification process later and will lead you to 12 steps which are part of PDCA cycle. ISMS certification process utilized Plan-Do-Check-Act (PDCA) cycle methodology which continually improve information security management system and meet the contractual, legal, and regulatory requirements for information security.

ISO assessment is utilized to analyze the current security posture of an organization where each control is defined and can be color coded using the base definition found in CMMI. Therefore ISO assessment is a great first step towards the final ISO 27001 certification audit or for that matter any compliance audit.

[TABLE=2]

ISO 27k framework for today’s security challenges
httpv://www.youtube.com/watch?v=yRFMfiLbNj8

Three useful titles on ISO 27k by Alan Calder

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Tags: Capability Maturity Model Integration, CIA scale, Information Security, Information Security Management System, International Organization for Standardization, isms, iso 27001, iso 27002, ISO/IEC 27001, PCI, PDCA, Risk Assessment, Risk management, Security, SOX HIPAA, vsrisk

Jan 14 2009

Cyber warfare and possibility of cybergeddon

Category: Information Warfare — DISC @ 1:56 am

Ā 

Background and Risks Associated with Various SCADA Systems | Envista Forensics

Cyber warfare poses a serious threat to critical infrastructure of a country. It has been a major challenge for DoD officials, cyber attackers have already stolen tera byte of data from their infrastructure.

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Most of the security expert and FBI agree that cyber attacks pose biggest threat to US vital infrastructure. ā€œCybergeddonā€ our daily economy which depend on inter connected vital network infrastructure is hacked by cyber attacker.

SCADA (Supervisory Control and Data Acquisition – control power grids in all the utilities) ā€œsystems are used in industry to monitor and control plant status and provide logging facilities and are highly configurableā€œ. SCADA system is a connection between control systems and the switches.

Cyber attackers have already led to multicity power outage outside of US. Recent attacks show that cyber attackers are getting more knowledgeable about SCADA system. In the past SCADA use to be exclusive system but now slowly getting integrated with the rest of the infrastructure and utilizing IP addressing scheme. Both introduce new threats and raise the risk of cyber attack.

Utilities are the most critical infrastructure in a sense because of other vital infrastructure dependency on power supply. Cyber attack on SCADA system has a potential of cybergeddon and should be protected as a very critical asset by both public and private sectors. Security through obscurity is not the answer for SCADA anymore.

Ā 

In SCADA system, reasonable security can be achieved by embracingĀ ISO 27kĀ standard as a policy and eventually acquiringĀ ISO 27001Ā (ISMS) certification. Organizations may start the certification process with limited scope (of critical processes) in the beginning, and increment the scope in each recertification attempt based on the resources available and management risk appetite.Ā Information Security Management SystemĀ (ISMS) can be a great value added process to manage ongoing monitoring, maintaining and for process improvement of SCADA.Ā ISMSĀ as a process in-place provides reasonable security safeguard to zero day attacks.

Ā 

How do I prepare for a power outage?

Ā 


Ā 

ā€œSCADA system has been poorly managed for decadesā€

What is SCADA?

Tags: Cyber-warfare, cybergeddon, Information Security Management System, Information Warfare, International Organization for Standardization, ira winkler, iso 27001, SCADA, Security

Nov 04 2008

Open Network and Security

Category: Information Security,Open Network — DISC @ 7:54 pm

Made and uploaded by John Manuel - JMK{{#if: |...

Open networks are heterogeneous environment where users like to use all the applications and systems at any given time. In a heterogeneous environment, each department run different hardware and software, but you can control the protocols which will work on this environment.

Universities are famous for open network. Most Universities network is comprised of a Bank (To give loan to students), a restaurant, and a bookstore which have credit card processing ability. Students, alumni, researchers, employee and staff need access to utilize resources. Now how would you control access if same person assume all the roles mentioned above. Universities are basically transient communities, where users come back and plug-in their new devices and expect an immediate access to all the resources. Where the reputation of openness is challenge at every step of the way, now the question is how can they maintain reputation and yet control the environment based on security policies.

Reasonable security can be accomplished by focusing on a process rather than adding yet another security control. The process is based on risk assessment program where you assess your critical assets based on threat and vulnerability pair and measure the likelihood and impact of a threat if a given vulnerability is exploited.

The process start with knowing your assets ā€“ Network registration will detect when you plug-in your new equipment. Before you get an access, it detects a hardware address and username. You can also control common misconfigurations and noncompliance issues with network registration process. Some vulnerability management systems discover assets and perform vulnerability and security configuration assessment to proactively identify and prioritize risks. New vulnerabilities are accessed from trusted site on a regular basis and when vulnerabilities are identified, the management system needs to have an ability to remediate to comply with the information security policy.

Most of the departments in an open network contains different systems and applications and basically have different security appetite. Distributed IT Governance can address this issue where you develop policies and procedures which fit their needs and hand it over to the department to comply.
Open network requires pretty much open borders, Instead of securing the network/system emphasis should be on data protection.

[TABLE=9]

Recent news from AT&T to make its network open where customers can use any handset of their choice, perhaps a reaction to in response to recent moves from Verizon and Google to promote open network. Specifically Verizon announced that it would allow ā€œany deviceā€ and ā€œany applicationā€ to operate on its network. These open networks does provide flexibility for customers but at the same time burden lies on the shoulders of the corporations to provide right balance of security and privacy with availability of the network.

In an open network, reasonable security can be achieved by embracing ISO 27k standard and eventually acquiring ISO 27001 (ISMS) certification. Information Security Management System (ISMS) can be a great value added process to manage ongoing monitoring, maintaining and for process improvement of an open network. ISMS as a process in-place provides reasonable security safeguard to your information and certainly help to minimize the liability in the court of law.

End-to-End Network Security: Defense-in-Depth by Omar Santos
httpv://www.youtube.com/watch?v=zTJSMjYd9c4

(Free Two-Day Shipping from Amazon Prime). Great books

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Tags: AT&T, Computers, Credit card, data protection, heterogeneous, impact, Information Security, Information Security Management System, isms, iso 27001, ISO 27k, ISO/IEC 27001, IT Governance, likelihood, Network registration, Omar Santos, Reasonable security, risk assessment program, security controls, threat, Universities network, Verizon, vulnerability, vulnerability management systems

Oct 21 2008

12 Phishing Threats and Identity Theft

Category: Email Security,Identity Theft — DISC @ 7:22 pm

Have you ever thought of losing something and you cannot live without it? Yes, that something can be your identity. Phishing is a practice of luring unsuspecting Internet users to a fake Web site by using authentic-looking email with the real organization’s logo, in an attempt to steal passwords, financial or personal information. In daily life people advise to retrace your steps when you lose something. The question is how you retrace your steps on cyberspace where some uber hackers know how to erase their footsteps to avoid detection. It is difficult to find phishers in cyberspace, and jurisdictional issues make it even harder to prosecute them. Then there is an issue of trust that phishers dupe people to believe that their web site is not fraudulent to collect personal/financial information.

Amongst the financial crisis, phishing might be on the rise because for many organizations information protection might be the last thing on their mind. The FDIC has created a webpage to inform and warn consumers about ā€œphishing.ā€ These days phishers have targeted social network organizations LinkedIn and Facebook where their members have been duped into revealing their sensitive data.

Mainly phishing attacks are targeted to steal the identity. Now the question is, how easy it is to steal somebodyā€™s identity? Letā€™s say a phisher has your name and address, and then he/she can get your Social Security number with the search on AccurInt or other personal database website. A Social Security number is not the only bounty a fraudster can find on these websites, other personal/private information is available as well at minimal cost.

In the table below are the 12 threats to your online identity which can be manipulated in phishing scams, and possible countermeasures to protect your personal and financial information. Some threats are inadequate or no security controls in place. The last row of the table is a monitoring control to identify the warning signs of identity theft.

[Table=7]

Organizations should take necessary steps to protect against identity fraud and apply whatever state and federal legislation applies to your business. Organizations which are serious about their information security should consider implementing the ISO 27001 (ISMS) standard as a best practice, which provides reasonable due diligence to protect and safeguard your information.

US Bank phishing attack exposed
httpv://www.youtube.com/watch?v=n2QKQkuSB4Q


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Tags: accurint, countermeasure, cyberspace, due diligence, equifax, experian, facebook, fdic, financial crisis, fraudster, identity fraud, information protection, isms, iso 27001, jurisdictional, legislation, linkedin, phishing, prosecute, safeguard, social security, threats, transunion, uber hacker

Oct 07 2008

vsRisk and security risk assessment

Category: ISO 27k,Security Risk Assessment — DISC @ 3:18 pm

Information Security Risk Management for ISO27001 / ISO27002

The State of California has adopted ISO/IEC 27002 as its standard for information security and recommends other organizations and vendors to use this standard as guidance in their efforts to comply with California law.

To achieve an ongoing compliance, major organizations require tools to comply with standard such as ISO 27002/ISO27001. vsRisk is an easy to use Information Security Risk Assessment tool which makes risk assessment process consistent, easier and produces required documentation to achieve ISO 27001 certification . vsRisk also aligns seamlessly with standards like ISO 27002, ISO 27005 and NIST SP 800-30.

vsRisk helps organizations to develop an Information Security Management System (ISMS) asset inventory and capture business, legal and contractual requirements against each asset. vsRisk is customizable to meet specific needs when introducing new risks, vulnerabilities and controls without any additional help from a consultant. vsRisk helps you focus on assets rather than on threats and vulnerabilities. This is an approach which works by treating business processes as an asset, which is examined for their criticality, lack of security and consequences of failed process can be examined. In this regards, vsRisk is an effective and efficient tool by identifying most important points and key issues right away, which focusing on threats doesnā€™t.

Major benefits of vsRisk tool:
1. It is the definitive ISO27001 risk assessment tool, compliant
with all the key information security standards – which means that
you can be certain that a vsRisk risk assessment will help you
achieve ISO27001 certification.
2. It is designed to be usable – your lead risk assessor and any
asset owners involved in your risk assessment are going to find
their task made easier
3. Unique features include the risk assessment wizard, which
standardizes the risk assessment process and guides asset owners
through the risk assessment process.
4. vsRisk creates a baseline from which future risk assessments can
easily be made.
5. vsRisk integrates with ISMS documentation toolkit, for even
greater usability.

ā€œvsRiskā„¢- the Definitive ISO 27001: 2005-Compliant Information Security Risk Assessment Tool, which automates and delivers an ISO/IEC 27001-compliant risk assessment and can assess confidentiality, integrity and availability for each of business, legal and contractual aspects of information assets – as required by ISO 27001. Providing a comprehensive best-practice alignment, it supports ISO 27001 and 27002 (ISO/IEC 17799) disciplines, and is ISO/IEC 27005 and NIST SP 800-30 compliant. It also offers a wizard-based approach that simplifies and accelerates the risk assessment process, plus integrates and regularly updates BS7799-3 compliant threat and vulnerability databases.ā€

The key to successful Risk Management is to protect your most important/critical assets. The importance/criticality of an asset might change over time. That is another reason to automate security risk assessment process to recalibrate your risks based on current state of security.

Risk Management to ISO27001/NIST Wizard-based risk assessment tool Simplifies compliance – To buy vsRisk tool!

Meet Stringent California Information Security Legislation with Comprehensive Toolkit

ISO27001 EXPERTS CAN HELP COMPANIES MEET STRINGENT CALIFORNIAN …
EIN News (press release) – Netherlands
vsRiskā„¢- the Definitive ISO 27001: 2005-Compliant Information Security Risk Assessment Tool, which automates and delivers an ISO/IEC 27001-compliant risk …




Tags: asset owner, automate security risk assessment, baseline, california, isms, iso 17799, iso 27001, iso 27001 certification, iso 27002, iso 27005, nist sp 80-30, sb 1386, vsrisk

Aug 25 2008

Laptop security and vendor assessment

Category: Laptop Security,Vendor Assessment — DISC @ 2:37 am

Another report of a laptop stolen, this one containing reams of sensitive customer information. The laptop was later returned in the same office complex, to a room which was reportedly locked; however, the sensitive data on the laptop was not encrypted.

According to a San Francisco Chronicle article by Deborah Gage (Aug 6, 2008, pg. C1): ā€œA laptop containing personal information on 33,000 travelers enrolled in a fast pass program at San Francisco International Airport turned up Tuesday in the same airport office from which it had been reported missing more than a week ago.
The machine belongs to Verified Identity Pass, which has a contract with the TSA to run Clear, a service that speeds registered travelers through airport security lines. Verified Identity operates the program at about 20 airports nationwide.
The computer held names, addresses and birthdates for people applying to the program, as well as driver’s license, passport and green card information. But, she said, the computer contained no Social Security numbers, credit card numbers, fingerprints, facial images or other biometric information.
Travelers in the Clear program pay to have the TSA verify their identities. In return, they receive a card that gives them access to special security lanes in airports so they can avoid standing in line to go through security.
The TSA said in a statement that Verified Identity was out of compliance with the administration’s procedures because the information on the laptop was not properly encrypted. Now the company must undergo a third-party audit before Clear can resume, the TSA said.ā€

When TSA states that the vendor (Verified Identity) was out of compliance, does that make the vendor liable for negligence? Not unless this was stated clearly in the contract that the vendor will be liable if customersā€™ private data is exposed unencrypted. Which means private data should be encrypted if itā€™s at the server, in transit or on the laptop.
This brings the question if the 3rd party service provider (vendor) should be considered for the security risk assessment and how often. This question should be considered before signing a service contract with the vendor and what criteria or standard should be used to assess the vendor. Should this assessment include the security office 3rd party cleaning staff, perhaps yes, considering sometime cleaning staff does have an access to very sensitive areas in the organization? Many of the controls applied to contractors should be more or less the same as applied to regular employees but the contractor who has access to sensitive information potentially should have more controls then the regular employees, which should be clearly defined in the service contract.
Before signing the service contract, due care requires the organization should always assess the vendorā€™s security posture based on their own information security policy and ISO 27002 standards. Depending on the risk assessment report, the organization can negotiate the controls necessary to protect the security and privacy of their data and customers with given vendors. At this point the organization needs to make a decision, if the vendor is up to par as far as information security is concerned and if negligent, give them some sort of deadline to improve controls to become a business affiliate. Depending on the level of data sensitivity, some vendors might be required to acquire ISO 27001 certification to become a business partner. This clause should be clearly included in the service contract.
Assessing the vendor on a regular basis might be the key to know if they are complying with the required security clauses mentioned in the service contract and make them potentially liable for non-compliance. If the vendor fails the assessment the organization should follow up with the vendor to remediate those gaps within a reasonable time frame, otherwise this constitutes a breach of the contract.

Laptop Security
httpv://www.youtube.com/watch?v=dytZBBlDMJs


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Tags: assessment, business affiliate, compliance, data sensitivity, iso 27001, iso 27002, laptop stolen, privacy, service contract, social security numbers, TSA, verified identity

Aug 08 2008

PCI DSS significance and contractual agreement

Category: pci dss,Security Compliance — DISC @ 11:52 pm





The PCI DSS (Payment Card Industry & Data Security Standard) was established by credit card companies to create a unified security standard for handling credit card information.  The retail service industry now understands the strategic significance of PCI DSS compliance, which was demonstrated when TJX announced that their system was compromised for more than 17 months, where well over 50 million customersā€™ credit and debit cards were breached. Retail business which fails to comply will be subject to penalties and fines, possibly lawsuits, and may lose their credit card processing capability. Non-compliance will not only expose businesses to fines and penalties but also make it vulnerable to many threats, which can exploit the vulnerabilities in the system and put your business to unnecessary risk. These risks could have been avoided with some due diligence. When business is non-compliant, any major breach will have a significant impact on business viability.


To start a process of PCI compliance, a merchant should determine if PCI DSS applies to their organization.  PCI DSS is applicable if your customer PAN (Primary Account Numbers) is stored, processed or transmitted in your organization. After determining the applicability of the standard, the merchant needs to determine where their business falls in the categorization of businesses by their bank in terms of merchant level.


Before commencing the risk assessment the assessor will perform the system profile to determine the applicability of the scope and set the boundaries of the system covered under PCI-DSS assessment. Planning is the key to success of a project; this is the phase where all the planning and project preparation will take place.   Now the key to the success of your on-going compliance is to simplify the scope of the project. The best way to achieve this to put all the PCI related assets in a precise segment to limit the merchant card holder environment.


Comprehensive risk assessment will be performed on the identified scope where risk analysis will identify the gaps based on PCI DSS standards and risk rating will prioritize the gaps for risk management.  Thorough risk analysis will generate a quality technical and process gap analysis, where you decide the mitigation/compensating controls to comply with PCI DSS.  After completion of the risk assessment the task of the risk management begins, to eliminate the gaps in your environment and to comply with the standard. Depending on the numbers of gaps the risk management team should set realistic goals to complete the tasks in hand.  Best practices recommendations suggest that the organization should eliminate/mitigate the high risks (high impact & probability) gaps to the organization, but sometime organizations decide to go after the low hanging fruits to start with their risk management process.


When the risk management process gets close to finishing and you are well on your way to comply with PCI DSS, you might think that perhaps your job is done. Well in a way, itā€™s just a beginning of a process where your organization is supposed to maintain the compliance with PCI DSS.  Based on expert opinion, PCI DSS is a process not a project. What you have done so far, is baseline your environment. Ongoing compliance is achieved by monitoring the relevant PCI DSS controls. Ongoing compliance will depend on the quality of the merchantā€™s information security management system (ISMS). A strong  ISMS would include thorough monitoring, logging and reviewing controls to maintain and improve system security over time.  You can develop an automated PCI monitoring process to achieve consistent results and sustain compliance by continuously monitoring your system. ISMS (based on ISO 27001) certainly can be a great value to manage ongoing monitoring, maintenance and improvement cycle.


In a sense, PCI is neither a regulation nor a standard but a contractual agreement between the merchant and their acquirer bank, when merchants start transmitting PAN data that makes them contractually obligated to comply with PCI DSS. To understand their obligations, the merchant should make a proactive effort to understand their acquirerā€™s particular interpretation of PCI DSS requirements to get compliant.  Ongoing compliance will require adequate resources and automated controls in place to routinely monitor, maintain, review and improve the required systems. Ultimately, ongoing PCI compliance will enhance business efficiency and reduce the potential impact of adverse publicity on your business image.


 












Documentation Compliance Toolkit

PCI Compliance

Practical guide to implementation (Soft Cover)

Practical guide to implementation (Download)



PCI Compliance
httpv://www.youtube.com/watch?v=0NUTs-aFtOA




Tags: business efficiency, business image, compensating controls, comprehensive, contractual agreement, gap analysis, isms, iso 27001, merchant card holder, mitigate, pan, pci compliance, pci dss, risk analysis, Risk Assessment, risk management process, tjx

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