Are You Prepared to Successfully Pass a PCI-DSS and/or a FISMA Certification Assessment? Fiona Pattinson, SHARE: Seattle 2010

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1 Are You Prepared to Successfully Pass a PCI-DSS and/or a FISMA Certification Assessment? Fiona Pattinson, SHARE: Seattle 2010 atsec information security, 2010

2 About This Presentation About PCI assessment and FISMA accreditation Structure and requirements of the prgrams How to prepare Avoiding common pitfalls FISMA= Federal Information Security Management Act PCI = Payment Card Industry atsec information security,

3 Terminology Accreditation and Certification PCI SSC: accredit companies and individuals as competent to perform assessments FISMA: certifies a system then it is accreditted to operate Assessment vs Audit Audit: somewhat jeaoulsly guared by the financial audit profession. Some potential for confusion over auditors assessing the compliance to the standards, vs system audit (logging) PCI SSC= PCI Security Standards Council atsec information security,

4 PCI Assessment What: Compliance with the PCI DSS Why: Mandated by the major credit card brands Who: Any organization storing, processing or transmitting credit card data When: Annually How:Depending on the level determined by the card brand compliance is assessed by using an SAQ A QSA accreditted through the PCI SSC Goal: Report of Compliance (Passing!) DSS= Data Security Standard PCI SSC= PCI Security Standards Council QSA= Qualified Security Assessor SAQ=Self Assessment Questionnaire atsec information security,

5 FISMA Certification Assessment What: Compliance standards and guidelines developed by NIST Why: It is mandated through FISMA Who: U.S. Federal government executive agencies, Their contractors and third parties processing their data excluding the DoD, CIA, and National Security Systems. When: Annually How: Certification Goal: System Accreditation (to operate). CIA= Central Intelligence Agency DoD= Department of Defense NIST= National Institute of Standards and Technology atsec information security,

6 What? Both PCI and FISMA! If your operations include storing, transmitting or processing credit card data for, or on behalf of a US government agency then you will need to comply with both schemes. atsec information security,

7 PCI DSS Structure and Requirements The PCI SSC was founded by five international payment card brands in American Express, Discover Financial Services, JCB International, MasterCard Worldwide, Visa, Inc. The PCI SSC mission includes developing and maintaining common security standards across the brands Mandated via each brands contractual agreements, and card brand security programs atsec information security,

8 Card Brands Security Programs Security Program The MasterCard Site Data Protection Program (SDP) Visa Cardholder Information Security Program (CISP) American Express Data Security Operating Policy Compliance Program (DSOP) Discover Information Security & Compliance (DISC) JCB URL ent/cisp_overview.html nt/singlevoice/dsw/frontservlet?request_type =dsw&pg_nm=spinfo&ln=en&frm=us&tabbed =compliencerequirement /disc.html All use the current version of the PCI DSS (currently 1.2.1) which is available from atsec information security,

9 PCI DSS Structure and Requirements The PCI SSC was founded by five international payment card brands in 2004, American Express Discover Financial Services JCB International MasterCard Worldwide, Visa, Inc. The PCI SSC mission includes developing and maintaining common security standards for the card brands Compliance is mandated via each card brand s contractual agreement(s) and security program atsec information security,

10 PCI DSS Structure and Requirements The Twelve Key Requirements of PCI DSS Build and Maintain a Secure Network Protect Cardholder Data Maintain a Vulnerability Management Program 1. Install and maintain a firewall configuration to protect cardholder data. 2. Do not use vendor-supplied defaults for system passwords and other security parameters. 3. Protect stored cardholder data. 4. Encrypt transmission of cardholder data across open, public networks. 5. Use and regularly update anti-virus software. 6. Develop and maintain secure systems and applications. atsec information security,

11 PCI DSS Structure and Requirements The Twelve Key Requirements of PCI DSS Implement Strong Access Control Measures Regularly Monitor and Test Networks Maintain an Information Security Policy 7. Restrict access to cardholder data by business need-to-know. 8. Assign a unique ID to each person with computer access. 9. Restrict physical access to cardholder data. 10. Track and monitor all access to network resources and cardholder data. 11. Regularly test security systems and processes. 12. Maintain a policy that addresses information security. atsec information security,

12 PCI DSS Structure and Requirements Card brand program requirements Annual assessment of compliance with the PCI DSS Quarterly Requirement for external network vulnerability scanning by an ASV COTS Payment Applications must be from the approved list ASV = Approved Scanning Vendor COTS= Commercial Off The Shelf atsec information security,

13 PCI DSS Structure and Requirements PCI DSS detailed requirements summary Penetration testing and internal network vulnerability scanning on major network changes Full mapping from high level security policy through configuration standards to implementation Secure programming standards Organizational, process and HR policies ASV = Approved Scanning Vendor COTS= Commercial Off The Shelf HR= Human Resource atsec information security,

14 FISMA Structure and Requirements FISMA The Federal Information Security Management Act of 2002 (Public Law (P.L.) ) Provides a comprehensive framework for ensuring the effectiveness of information security controls over information resources that support Federal operations and assets. Gives NIST authority to produce standards (FIPS) and guidance (SP) to support the FISMA objectives FIPS are compulsory and binding for federal agencies SPs are recommendations and guidance documents. Federal agencies must follow SPs mandated in a FIPS. FIPS = Federal Information Security Processing Standard SP= Special Publication National Security Systems are excluded atsec information security,

15 FISMA Structure and Requirements Uses a Risk Management Framework Classifies systems as Low, Medium and High Apply a baseline set of controls according to the system classification May augment and improve the baseline control set atsec information security,

16 FISMA Structure and Requirements RMF = Risk Based Frame work From atsec information security,

17 C&A phases 1. Initiation (i) preparation (ii) notification and resource identification (iii) system security plan analysis, update, and acceptance 2. Security Certification (i) security control assessment; (ii) security certification documentation. 3. Security Accreditation (i) security accreditation decision (ii) security accreditation documentation. 4. Continuous Monitoring (i) configuration management and control; (ii) security control monitoring; (iii) status reporting and documentation. atsec information security,

18 An Approach for Compliance The first time is always the hardest. Build security measurement, and assess-ability into the business processes. Always be ready for an assessment A properly prepared organization shouldn t need to do much preparation. They should be ready at ANY time. Be aware of changes in the standards. Keep up to date with them. Reviewing for changes once a year a month before the assessment leads to problems. atsec information security,

19 An Approach for Compliance Understand the assessment requirements and how z/series supports you in meeting them. There may be differences in how controls can be met or interpretations needed for your environment. E.g.: Malware requirements in PCI DSS File Integrity Checking for PCI Have a GOOD and effective risk management process. That matches YOUR organization Specify compensating controls wisely Too many are a red flag: but they are probably necessary! atsec information security,

20 An Approach for Compliance Reuse other assessment results PCI DSS, FISMA, ISO/IEC 27001, SAS/70, SOX, EuroSOX etc all provide (independent) controls assessments. Do not reinvent the wheel! Check for assurance given by product certifications including Common Criteria, FIPS etc. Vendors spend a lot of resource and money giving you this assurance. Use it! Integrate security management systems: Each assessor needs to make his or her own determination, but you can be smart! Awareness training, HR processes, internal audit of organizational processes and others can, with a little organizational agility, be shared. atsec information security,

21 Doing both. What is in Common? Risk Management Both PCI and FISMA take a baseline approach to cover the industry-level risks Both require that you perform your own risk process too. To include organization specific risks Many of the controls are the same or very similar Too much detail for THIS presentation Several commercial tools provide mapping Training and Awareness Internal audit Especially process and management controls Document and Record control atsec information security,

22 An Approach for Compliance This approach can be used for combining almost any set of management systems compliance schemes atsec information security,

23 Pitfalls: Passion Those who want to do security because it s the right thing to do are invariably more successful and suffer less incidents than those who just want to pass the assessment to allow them to continue to operate. Management Commitment to the intentions of the scheme helps a lot. atsec information security,

24 Pitfalls: Time! I need a RoC in three weeks or I can t do business Know your deadlines Know the critical path If it is the first time through invest in a gap analysis by someone who knows the standards & your technology well. Allow plenty of time for remediation atsec information security,

25 Pitfalls: Scoping Scoping: Not too big nor too small It is worth spending a lot of effort on getting this right. Keep sensitive data to a minimum and reduce scope creep. Use what you can to reduce scope: Know the rules and know your technology! atsec information security,

26 Benefits of Large Computer Systems Better physical protection Better logical separation (via PR/SM and z/vm) Higher reliability Better isolation of development and production Better separation of operation and configuration / maintenance Better separation of duties More automated processing Extensive monitoring and auditing capabilities

27 Pitfalls of Large Computing Systems Large, complex environment Tons of security critical configuration options Requires careful use and assignment of access rights and privileges High reliability implies high redundancy also of critical data Customer developed system exits, SVCs and authorized programs often introduce critical vulnerabilities Developers are often not aware of the precautions they need to take This is often also true for third-party software atsec information security,

28 Pitfalls: Choosing Your Assessor Choosing you assessor (skills and competency) Have they experience with mainframes Do they understand the additional security built in to such systems, or do they try and map it to more common paradigms? Conflict of Interest Don t choose assessor that tries to sell you their product, a partners product, or consultancy Transfer of Risk! Your assessor assumes risk when they make statements about your systems. Are they mature enough to realise this? atsec information security,

29 Pitfalls: Snake Oil & Silver Bullets Unfortunately there are no Silver bullets Magic tools Wonderous applications atsec information security,

30 Summary atsec information security,

31 Bibliography PCI Security Standards Council NIST FISMA Program PCI compliance for Large Computer Systems Comparison of Common Criteria Functionality and FISMA controls Comparision-with-atsec-evaluated-Linux-OS.pdf 'Strategies for the Integration of Management Systems and Standards', The TQM Magazine, vol. 14, no. 1, pp Karapetrovic, S. 2002, atsec information security,

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