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PCI DSS 3.2 – Important 31 January 2018 Deadline & Clarifications

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Overview

In April 2016, Version 3.2 of the Payment Card Industry Data Security Standard (PCI DSS) was released. This new version of the standard contains a number of new requirements which come into full force as of 1 February 2018. This document provides an overview of what is new in Version 3.2, separated by:

  • Clarification of requirements that came into force for all Version 3.2 reports.
  • New requirements that come into force for all parties (merchants and service providers) as of 1 February 2018.
  • New requirements that come into force for service providers only as of 1 February 2018.
  • Sunset date for SSL and Early TLS.

This document summarises what Confide has seen from assessments undertaken since Version 3.2 was released and the information that has been provided by the PCI Security Standards Council.

Clarification (Applicable for all 3.2 reports)

1.1.6.a: Identify the firewall and router configuration standards document(s) reviewed to verify the document(s) contain a list of all services protocols, and ports necessary, including a business justification and approval for each.

These approvals should be granted by someone other than a person who is responsible for managing the configuration. For example, this might include a Security Officer or other role who is responsible for overseeing the PCI DSS process internally, or by someone outside of the standard team of people who are responsible for performing the day to day management of network devices.

6.5: Address common coding vulnerabilities in software-development processes as follows:

  • Train developers at least annually in up-to-date secure coding techniques, including how to avoid common coding vulnerabilities.
  • Develop applications based on secure coding guidelines.

The requirement for developer training is not new. However, in Version 3.2, it was clarified that this training must take place for all developers at least annually. We also recommend that testers attend this training as well to ensure that they are adequately equipped to test for basic security vulnerabilities.

11.3.4.c: Verify that the [segmentation penetration test] was performed by a qualified internal resource or qualified external third party, and if applicable, the organisational independence of the tester exists (not required to be a QSA or ASV).

The requirement for segmentation testing is not new. However, in Version 3.2, a clarification was made that brings the requirement for how segmentation penetration testing into line with the requirements for internal and external penetration testing. The person performing the segmentation testing must be either a qualified internal resource or external third party, and there must be sufficient organisational independence (e.g. the penetration testing should not be done by individuals who are responsible for the day to day management of the systems or who report directly to staff who are responsible for these teams).

12.3.3: Verify that the usage policies define:

  • A list of all critical devices, and
  • A list of personnel authorised to use the devices

The wording of this requirement has been adjusted to ensure that it is clear that the usage policies must include both a list of the critical devices in the environment and a list of the personnel authorised to use the devices. This needs to be documented and cannot be considered “self-documenting” as part of a system such as Active Directory or LDAP.

Additional Requirements for All Parties (as of 1 February 2018)

There are several new requirements that come into force for both merchants and service providers.

6.4.6: Upon completion of a significant change, all relevant PCI DSS requirements must be implemented on all new or changed systems and networks, and documentation updated as applicable.

To ensure that this requirement is met, Confide recommends that a clear definition of what constitutes a “significant change” be defined within the processes so that it is possible for staff to identify when this level of review is required. While the PCI Council does not provide a definitive definition of what constitutes a significant change, guidance from Requirement 11.2 suggests this includes (but is not limited to):

  • New system component installations
  • Changes in network topology
  • Firewall rule modifications
  • Product upgrades
  • Operating system upgrades
  • Sub-networks being added to the environment
  • New web servers

Once significant changes have been defined, we recommend developing a set of templates for reviewing the relevant PCI DSS requirements to ensure that both (1) the relevant requirements have been put in place prior to the system going live, and (2) sufficient testing has been done to meet the requirements for PCI DSS (e.g. penetration testing, vulnerability scanning, etc.) Incorporating this into the change control process is one option.

8.3.1: Incorporate multi-factor authentication for all non-console access into the CDE for personnel with administrative access.

The PCI Security Standards Council recently published a guidance document on what constitutes multi-factor authentication (see: https://www.pcisecuritystandards.org/pdfs/Multi-Factor-Authentication-Guidance-v1.pdf.

In this document they provide a number of examples of what does and does not constitute multi-factor authentication and where multi-factor can be placed in the environment. We also recommend reviewing the PCI Security Standards Council’s guidance on Segmentation and Scoping (see:

https://www.pcisecuritystandards.org/documents/Guidance-PCI-DSS-Scoping-and-Segmentation_v1.pdf as the way that multi-factor is implemented may be influenced by how you have decided to segment the environment.

Additional Service Provider Requirements (as of 1 February 2018)

These new requirements are currently only applicable to service providers. As defined by the PCI DSS, a service provider is any business that is directly involved in the processing, storage, or transmission of cardholder data on behalf of another organisation, or that otherwise impacts the security of cardholder data.

3.5.1: Maintain a documented description of the cryptographic architecture that includes:

  • Details of all algorithms, protocols, and keys used for the protection of cardholder data, including key strength and expiry date
  • Description of the key usage for each key
  • Inventory of any HSMs and other SCDs used for key management

While policies and procedures for key management and the management of encryption devices has long been required, this requirement set out a new level of detail that must be documented around how cardholder data is protected. In part, this also helps the organisation to keep up with evolving threats to the architecture, and to be able to detect lost or missing keys or associated devices.

10.8: Implement a process for the timely detection and reporting of failures of critical security control systems, including but not limited to failure of:

  • Firewalls
  • IDS/IPS
  • FIM
  • Anti-virus
  • Physical access controls
  • Logical access controls
  • Audit logging mechanisms
  • Segmentation controls (if used)

This requirement is aimed at addressing the increased threat of intrusions going undetected for an extended amount of time. In order to ensure that there is a timely process for detecting failures in place, this requires a proactive process to be in place. There is not yet any clear guidance on what constitutes a timely manner. However, automated tools are likely to make this task significantly easier.

10.8.1: Respond to failures of any critical security controls in a timely manner. Processes for responding to failures in security controls must include:

  • Restoring security functions
  • Identifying and documenting the duration (date and time start to end) of the security failure
  • Identifying and documenting cause(s) of failure, including root cause, and documenting remediation required to address root cause
  • Identifying and addressing any security issues that arose during the failure
  • Performing a risk assessment to determine whether further actions are required as a result of the security failure
  • Implementing controls to prevent cause of failure from reoccurring
  • Resuming monitoring of security controls.

While this requirement relates directly to the incidents identified in Requirement 10.8, this requirement relates to the incident management procedures and extends the procedures in the event that a critical security control fails. Due to the newness of this requirement and the extensive reporting requirements that go along with it, we recommend that this process is tested as part of the process development to ensure that the processes can be embedded within the incident processes for the organisation.

11.3.4.1: If segmentation is used, confirm PCI DSS scope by performing penetration testing on segmentation controls at least every six months and after any changes to segmentation controls/methods.

While this is a new requirement, it extends the exiting requirement for organisations that use segmentation to test the effectiveness of that segmentation. This new requirement increases the frequency with which service providers must perform this testing. While there is no requirement for the testing to be done by an external, third party, any internal party must be both (1) able to demonstrate that they are appropriately qualified to perform the testing, and (2) that they are organisationally independent.

12.4.1: Executive management shall establish responsibility for the protection of cardholder data and a PCI DSS compliance program to include:

  • Overall accountability for maintaining PCI DSS compliance
  • Defining a charter for a PCI DSS compliance program and communication to executive management.

The remaining new requirements are focused on the overarching governance processes to help ensure that PCI DSS is not treated as a point-in-time event, but instead is integrated into the BAU processes. As part of that, there needs to be a commitment at the senior level to ensure that PCI DSS is visible at the executive level.

12.11: Perform reviews at least quarterly to confirm personnel are following security policies and operational procedures. Reviews must cover the following processes:

  • Daily log reviews
  • Firewall rule-set reviews
  • Applying configuration standards to new systems
  • Responding to security alerts
  • Change management processes

This requirement and Requirement 12.11.1 help to ensure that processes are regularly reviewed to ensure that they are being followed. While this requirement is not meant to repeat the testing from the PCI DSS requirements, understanding the underlying intention of each of these requirements should guide how the review process is carried out. This also helps to ensure that failures in processes can be identified early, so as to minimise the risk to PCI DSS compliance.

12.11.1: Maintain documentation of quarterly review processes to include:

  • Documenting results of the reviews
  • Review and sign off of results by personnel assigned responsibility for the PCI DSS compliance program.

This requirement ties together the review documentation from Requirement 12.11 and the governance processes from Requirement 12.4, and helps to ensure that there is a clear visibility into how processes that affect PCI DSS compliance are visible to senior management.

TLS Requirements (1 July 2018)

After 30 June 2016, all entities must have stopped use of SSL/early TLS as a security control, and only use secure versions of the protocol.

Prior to 30 June 2018, existing implementations that use SSL and/or early TLS must have a formal Risk Mitigation and Migration Plan in place.

Appendix 2 covers the requirements for SSL / Early TLS.

Given the impending deadline for disabling SSL and Early TLS, we recommend that reviewing the current need for these protocols is done on a more frequent basis to determine if it is possible to disable them prior to the deadline.

Confide is New Zealand’s Premier Security Assessment Company for the Payment Card Industry.

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What Are the Prerequisites for the CCNA?

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The CCNA is a Cisco certification required for most IT professionals. There are actually a few versions of the exam, but the most common is the CCNA Routing and Switching certification. This exam can be taken at the Associate level, so there aren’t many concerns as far as prerequisites go.

The only real limitations are that a person under 13 years will not be permitted to take it, and a person between 13 and 17 must have parental consent. For those 18 and older, there are no restrictions, as Cisco does not require any previous exams to become eligible for the CCNA.

Still, just because there are no real prerequisites, this doesn’t mean the exam isn’t challenging. It’s a 90-minute test consisting of both multiple-choice and performance-based questions. Anyone taking the exam will have to thoroughly prove their knowledge and problem-solving skills in a limited time. It can be stressful, and it’s recommended to have both theoretical knowledge as well as practical networking experience before taking the test. The following are the best ways to prepare for the CCNA.

Study materials

There are plenty of study materials that can get you started. These range from official study guides, video courses, labs, and more. There is a list of Cisco approved materials for those wishing to follow that path, though there are a variety of options from other vendors as well. Regardless of whether you pursue free or paid options, you’ll need to do your best to cover all of the content that could appear on the exam. The methods you choose will likely depend on your learning style.

In general, it’s recommended to take a self-paced video course, regardless of your knowledge level. These will generally measure your knowledge at the start of the course to ensure you aren’t bored with concepts you already know nor overwhelmed at the beginning with unfamiliar ideas. You’ll likely need some additional materials, however, as it can be easy to miss some ideas when watching videos.

There’s an official Cisco Certification Guide available in ebook and hardcopy forms which many argue to be the best study guide available. It’s also impossible to replace hands-on experience through any number of study guides or lab courses. Luckily, modern simulation tools like GNS3 can let you practice the majority of performance-based content you’ll see on the exam.

Practice tests

To get a better idea of what the real exam will be like, you’ll need to take some practice tests. While no practice test can show the same questions that will appear on the current exam, there are many tutoring packages out there that include a CCNA practice test with real questions from past exams. These questions are obtained directly from Cisco and Pearson and can give you a good idea as to the structure of the exam. If you’re able to complete these in the allotted time, you should stand a better chance at the real thing.

Additional preparation

No matter how you decide to prepare for the exam, you’ll likely be doing some combination of self-study and seeking outside help. External training options like expert boot camps and live courses may be just what you need if you require a more personal touch. These options generally include several hours of live instruction, and boot camps will let you schedule appointments with an expert instructor.

The real key is that you need to understand your own learning style and pace, something you’ll hopefully have good experience with from previous classwork. Luckily, you can have a combination of everything you think will work for you before you attempt your exam.

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5 Tech Jobs Guaranteed to Last

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With the rise of automation, not to mention artificial intelligence, the future of tech jobs from a human perspective can be a little uncertain. That being said, there are certain jobs in the tech sector that will not be going away, not until the machines rise up that is.

1. Database Administrator

DBAs (database administrators) take care of a company’s data. They make sure that their databases run efficiently and that they are secure from people that shouldn’t have access. A DBA will also be responsible for organising that data and storing it effectively. This role does generally require a degree in MIS (Management Information Systems) or in a related field.

Database administrators also need to have an understanding of database languages, the most common of which is SQL (Structured Query Language). Whichever programming language a company may use, the database administrator will have to be able to navigate it effectively.

2. Software Developer

The creatives behind a computer program are called software developers. Some will create applications, such as circuit board software, for example, while others will build systems. Software developers will usually work alongside computer programmers.

A bachelor’s degree in computer science is generally required of a software developer, that or in software engineering or another related field. In some cases, a degree in mathematics is acceptable too.

In addition to the above, a traditional academic education is not necessarily required due to ‘online coding boot camps’ that are often available free of charge.

 3. Web Developer

Developers that specialise in web applications will use various programming languages in order to create online software to client specifications. A web developer will normally be proficient in the use of multiple programming languages as well as operating systems.

An employer will look for computer-related education as well as relevant experience in the field. With these skills being in high demand, formal degrees are not usually required.

4. Computer Systems Analysts

A computer systems analyst is responsible for investigating an organisation’s systems and procedures. Following this, they will revamp or design these to help a company operate more efficiently. An analyst needs to have an understanding of both IT and business needs and their limitations. Responsibilities include liaising with managers to determine their IT related needs.

The majority of systems analysts have a bachelor’s degree in a computer related field, but they may also be required to have a business background.

5. Mobile Application Developers

Mobile application developers are responsible for creating or adapting existing applications for use on mobile devices such as smartphones and tablets. Video game studios, advertising companies and marketing companies recognise that mobile is an effective content distribution channel. Mobile application developers are in demand from other sectors too such as financial institutions, government agencies and those industries that require products to help their operations run more efficiently.

Many mobile application developers will have a background in either computer science or software engineering. There are now colleges that offer degrees in mobile application development so that’s another option to look at.

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IT Security

Take These Steps And Protect Your Business From A Cybercrime

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You might have read the news story surrounding the events that happened at Mal A Largo. The prestigious club favoured by the president was recently breached by a woman who claimed she was a member. She wasn’t. When she was inside, she suggested she was there for a conference.

There was no conference taking place and the woman entered the club with multiple pieces of tech. One of which contained malware data. The president was in the club at the time and it is not currently known what the woman’s intentions were. It is however clear, that she almost succeeded.

This shouldn’t come as a massive shock. After all, recent reports have suggested that by 2021 there will be a cyber attack on a business every twenty seconds. That’s crazy and it won’t just be big businesses that are exposed either.

Indeed, experts suggest that smaller companies will be targeted because criminals won’t expect them to have the latest protection measures in place.

This leaves an important question: Is your business secure and prepared for the threat of a cyber attack?

Truthfully, the answer is probably no. But you can take steps and make changes to ensure that your business is protected.

Let’s look at some of the ways you can do this, plus here’s a quick recap on what you need to know about cyber crime and malware.

What is Malware?

You don’t need to know the history of malware but it’s kind of interesting so here’s a short summary.  Its beginnings are thought to be in 1949, with  computer scientist John von Neumann, however the first documented viruses were in the 1970s.

There was the creeper worm by Bob Thomas and in the eighties the man credited as the father of viruses, Fred Cohen really developed the computer virus as we know it today.

Not all viruses are bad, though malware is and it’s thought that a third of all computers world-wide have been infected at some time.

Hard-hitting viruses

There have been some very hard hitting computer viruses over the years including:

  • 2013 – Cyptolocker. This is one of the early ramsonware programs. Ramsonware in itself is interesting insofar as it denies the user access to their computer with threats to publish the users’ data unless a ransom is paid.
  • 2014 – Backoff. Known for hitting the Point of Sale (POS) machines to steal credit card data.
  • 2016 – Cerber. One of the most infective viruses according to Microsoft.
  • 2017 – WannaCry Ransomware. Appropriately named as many companies attacked by it did ‘want to cry’.

Source – a brief history of malware

What is Cybercrime?

Simply put, cybercrime is the term given to describe any criminal activity online, i.e. uses the Internet. It’s far-reaching, insofar as it includes everything from ramsonware and other viruses, to hacking, phishing and spamming.

So, what can you do to make sure your business is protected?

Installed And Up To Date

It’s important to make sure that you are installing anti-virus software. Once it is installed, make sure that you are updating it regularly. Many people think that once you have installed anti-virus software on your tech, your issues are over. This just isn’t the case. Indeed, it’s instead possible and even likely that you fall behind on updates and suddenly there’s basically no protection for your business.

This is usually because people are relying on free antivirus software. Free software is better than nothing, but it’s definitely not the ideal solution. If you want the highest level of protection, then you need to invest in the best software on the market. This isn’t free but it does provide fantastic value for your company.

Choose Strong Passwords

Passwords are incredibly dangerous if they are easy to guess or if they include information that people could quickly access. As such, there should be no personal information used to create your passwords. It should be a random string of numbers and letters. These are almost impossible to guess or hack and as such will keep your sensitive data secure.

The Latest Tech

Do make sure that you are investing in the latest technology and equipment. The latest tech will usually have preventive measures in place to ensure that software is protected. Particularly if they are running the latest programs and systems.

You should be careful of methods for saving money as well such as BYOD initiatives. While this can cut costs down, you can’t guarantee that the devices that employees are as secure as they need to be. Investing in the latest technology yourself will always be the best option.

We hope this helps you understand how to secure your business from a potential cybercrime.

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