More than 75 percent of enterprises are holding off on deploying server virtualization in the cardholder environment until the PCI Security Standards Council clarifies its stance on virtualization, which they hope will come in the October 2008 release of the 1.2 version of the standards. That is a mistake.
Merchants and assessors interpret requirement 2.2.1 (which says, in essence, that a server is only allowed to have "one primary function") as prohibiting server virtualization. The PCI Knowledge Base is finding ample evidence—including the 75 percent above—that hesitation is now the norm.
But there really is no reason to wait. Why? The proof is in the tracking tools. Whether the 1.2 release of PCI DSS in October 2008 specifically addresses server, network and desktop virtualization is less important than being able to provide proof to your PCI assessor that you can control, manage and track access to card data continuously.
But the required controls are not standard issue in most implementations of server, desktop or network virtualization. There are a variety of add-on tools that you can buy that will give you the access control, monitoring and reporting tools that you need. Until the virtualization vendors buy and integrate these tools (or companies) into the "native" virtualization software, providing the evidence of compliance in a virtualized environment will require that you implement the necessary add-on tools.
PCI Assessor views should not stall virtualization deployment. If PCI DSS 1.2 does not specifically provide evidentiary requirements for secure virtualization, do not despair. As Branden Williams of VeriSign pointed out in his comment on my prior column on virtualization, it's not too hard to find an assessor who will sign off on server virtualization in the cardholder environment.
So your first task should be testing assessors regarding their position on virtualization and switching assessors if needed. If evidentiary controls for virtualization are not spelled out in PCI DSS 1.2, the task of convincing a PCI assessor becomes a "one off" activity. Since comparatively few assessors possess expertise in server, network or desktop virtualization, you may have to work with your assessor and vendor to determine what constitutes sufficient evidence for each of the key controls. In the end, the merchant who has the best tools stands the best chance of proving control effectiveness.
Virtualization, meet security and compliance. Having just returned from speaking at the Citrix Synergy conference on the impact of virtualization on PCI compliance, it is still clear that both the software vendors and the IT departments who are developing and implementing server, desktop and network virtualization do not have data security or PCI compliance on their list of requirements.
The focus (for very good reasons) is cost, availability and performance. Therefore, it will be up to security and compliance managers to play the role of "technology police" and ensure the necessary security add-on tools are put in place before virtualization is rolled out to application and database servers or desktops. Of course, the problem will be that security managers are not experts in virtualization either. So, there is some needed cross-education when it comes to this transforming technology.
The bottom line: Virtualization is moving far faster than security standards. Instead of resisting it and focusing on "letter of the law" interpretation of the PCI standards, I would argue that assessors, banks, security managers and security vendors need to educate themselves to understand not only the risks that come with virtualization but also the superior access controls, auditing and tracking tools that are available.
Then focus on developing a set of "proof points" and reporting requirements and share them among the vendors, merchants, assessors and banks. This should take place whether or not virtualization is part of the PCI DSS 1.2 standard, simply because it will help move the market forward and be better for the companies that implement the technology. If you have any questions about the topic or the tools that will provide these capabilities, send me E-mail at [email protected]