Which Do You Want, Buddy? Compliance Or Security?

Guest Columnist David Taylor is Research Director of the PCI Alliance, Founder of the PCI Knowledge Base, and a former E-Commerce and Security analyst with Gartner.

Only a small minority of retailers says that they are getting much value from their security investments.

Examples abound: Intrusion alerts that are ignored due to lack of staff, firewalls with rules that are out of date, intrusion detection systems that have not been tuned to minimize the false positives, encryption keys that are never changed, privileged users who have permissions left over from prior projects, terminated employees who still have logins, policies that are not enforced…. I could go on. Fixing this stuff is not expensive, but it's not fun either.

Last week, the Hannaford CIO discussed his grocery chain's breach publicly and said that, even though it was compliant, it needed to go well beyond PCI compliance in order to be secure. I couldn't agree more.

In fact, next week the PCI Knowledge Base is going to publish "The PCI Leadership Report," which will draw on more than 100 hours of anonymous interviews to highlight how PCI leaders are "going beyond" what their peers are doing to secure their environments. For you lucky StorefrontBacktalk readers, I'm going to highlight some of the key findings, to entice you to obtain the actual report next week.

Many of the merchants and assessors we interviewed see upper management as simply wanting to get PCI "over with," suggesting that the first to be compliant wins something, such as not getting fined by their bank. True leadership, however, is the security or compliance or project manager who goes to senior management and "makes the case" for doing more than the minimum. These are the bravest people of all, and true leaders.

Leadership by doing compliance right: PCI assessors have noted that a good percentage of merchants don't take PCI compliance seriously. They see evidence of last-minute scrambling to find access control logs, update policies and other "security creativity" as indications that companies view compliance as just another exercise to make the auditors go away. The merchants that have "operationalized" compliance are the true leaders.

Leadership by leading-edge technology: But even if a merchant has great procedures that are well documented, it still needs to have the right tools for the job. In the case of Hannaford, the CIO cited TDES PIN POS upgrades and a host-based IPS as part of their "beyond PCI" security (though the former isn't really beyond PCI). More common answers from the folks in the PCI Knowledge Base were implementation of SIEM, DLP and IAM, to throw out a few acronyms that you should either know or Google. Of course, I hasten to quote my ex-wife: "It's not your equipment, but how you use it" that matters, so having the skills to use these tools is also key.

Leadership by managing your risk: The folks in the PCI Knowledge Base often cited that lack of any real risk management plan or tool. Just because PCI requires 100 percent to pass doesn't mean that a merchant shouldn't try to measure its risk and apply technology and procedures differentially to address that risk. Leaders are the firms that use risk management results to drive their application of security controls.

Leadership by doing really boring things well: Even leading merchants with leading-edge technology have to do something with all the log data that is generated by the controls. If you want to be a leader, you actually have to review this stuff. In this case, the leaders are the merchants who have automated tools or services to help them "keep on top of" the mountains of data, so they can identify a potential breach before it becomes a reportable event under the 42-state breach reporting laws.

Leadership by protecting all confidential data: This was the theme of my last two columns. Going beyond just protecting card numbers to protecting other "confidential class" data is definitely a sign of leadership, because other types of data are also in demand by identity thieves and other "fraudsters" (which is such a cute word).

Leadership by securing the ecosystem: Many merchants (i.e., upper management) seem to have the view that once they get a letter or agreement from service providers saying that they are PCI compliant or otherwise promise data protection, that they are done worrying about their service providers and partners. Well, that's not a "leader" view. The leaders we talked to are the ones who are doing more due diligence regarding their partners and service providers. Some are sending out questionnaires, and leaders who can afford it are dispatching audit teams (their own or third-party auditors) to do onsite visits of their partners.

There are many "dimensions" of PCI leadership. By pulling together the perspectives of merchants, PCI assessors, acquiring banks, card processors and technologists, the PCI Leadership Report presents several best practices and advice, and provides some basic statistical analysis to give some sense of priorities.

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.

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