Last week, we pointed out that the leading merchants and financial institutions in the PCI Knowledge Base are applying the PCI controls to data other than credit card numbers because they found that it is easier to centrally manage a set of controls when they are based on a consistently enforced set of security policies.
One of the "hard parts" of extending PCI controls to other confidential data is the application of Identity and Access Management (IAM) that crosses applications and platforms, without encountering the "analysis paralyses" that comes with trying to implement Single Sign-on. Here we suggest a few practical things you can do.
Modify your security policies. It may be obvious to many that security policies should require the comparable protection of all data in a particular class. However, because many organizations created policies specifically to comply with PCI standards, there are some policies that specifically single out cardholder data for special protection. These need to be rewritten to reference a data classification policy. If that doesn't exist, then it needs to be created, and some examples of data in the "confidential class" other than cardholder data need to be provided.
Consider policy management tools. Once you have a complete set of security policies, you will likely find that managing compliance with them is not easy. I would recommend one of the various security policy management tools. For example, there are very useful tools from ArcSight, Archer Technologies, Braebeion and Compliance Spectrum, and that's just the beginning of the alphabet. I suggest you find a vendor who has a package for retailers and who knows something about which and how retail applications use what confidential data. This kind of tool will save you effort and reduce errors from failing to monitor access to some critical data. But, by themselves, these tools cannot limit access to your confidential data.
Integrate access controls into IAM. The problem with access controls is that there are too many ways to implement them and they are hard to organize. For example, some companies take a "top down" approach, by establishing an enterprise identity management system and using that to centrally manage access to all resources. That is probably the best way to do it.
But a good deal of the identity management software out there is platform specific (e.g., from Microsoft, Sun, Oracle, Novell). For those retailers with multiple platforms, you should probably consider a third-party software approach. But unless you're prepared to make a major commitment to running your business this way, you may want to stop short of "Single Sign-on" nirvana. For the near term, a reasonable approach is to implement tools that take advantage of Microsoft Active Directory, such as Centrify, NetPro, or others.
Generally, you'll find it easier to build on a tool you already have, than to go back and build IAM as an enterprise service. While this may sound "non-strategic," it is a practical approach to extending PCI compliance to address other types of data with limited budget. And that is where most people tell me they are today.
If you want to discuss this column or any other security or compliance issues, please send me an E-mail at [email protected] or visit www.KnowPCI.com and click "Get Involved" to join the PCI Knowledge Base.