Monthly ArchivesJanuary 2011

Seven Deadly Sins of a QSA (Part 6) standard

Sin #2 – Compensating Control Chaos Compensating controls are a challenging and somewhat confusing nuance to PCI DSS. In Chapter 12 of PCI Compliance: Understand and Implement Effective PCI Compliance I delve into this perceived “Get out of jail free” card. Many companies have found this a useful guide for creating compensating controls during their PCI DSS journey1. Compensating controls are designed to allow companies to meet the controls laid out in PCI DSS in alternate ways. For example, a company that cannot put Secure SHell (SSH) on all of their routers and switches due to technical constraints may be able to do something different that would meet requirements for a compensating control as laid out in the PCI DSS ...

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Seven Deadly Sins of a QSA (Part 5) standard

How to Avoid a Made Up Requirement The only way to avoid a made up requirement is to ensure that there is material in the PCI DSS that supports a recommendation before a it’s made. There are two main areas where you can find information on how to handle strange situations—PCI DSS itself as well as the FAQ that can be found on the PCI Security Standards Council’s website. The “Navigating PCI DSS” series is also useful, but supplementary and cannot be assessed against. Any guidance taken from documents other than the PCI DSS should be written up as a compensating control where appropriate. Additional documentation such as Special Interest Group (SIG) whitepapers, do not indicate changes in the standard ...

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Seven Deadly Sins of a QSA (Part 4) standard

Being a Security Professional Being a security professional can be a curse when logically thinking your way through compliance initiatives. No compliance initiative should be a substitute for a sound information security program, but we as security professionals often get caught in the compliance trap. We’ve been beating the security drum for years, yet our musical stylings have gone unappreciated. Enter a compliance initiative and all of the sudden someone is forcing the business to do what we’ve been telling them to do all along! We tend to take advantage of this new security spending windfall and add all kinds of stuff to purchase orders in the name of compliance. QSAs are guilty of this as well. Often times a ...

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Seven Deadly Sins of a QSA (Part 3) standard

Mis-hearing the Trainer QSAs must be pass evaluation from the Council every year in addition to earning at least forty CPEs in order to maintain their QSA designation. Prior to 2010, this meant finding a QSA Requal class near you and having your primary contact book your attendance in said class1. Trainers come and go as we have seen over the years, and I sat through a session with a good number of my team lead by a new trainer a few years ago. One of the most important steps a QSA must get right is choosing the correct scope for the assessment. Getting that step wrong sets the whole assessment and the PCI experience up for failure. This topic tends ...

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Seven Deadly Sins of a QSA (Part 2) standard

Sin#1 – Making Up Requirements One of the most common mistakes QSAs make is to simply make a requirement out of nothing. Don’t fool yourself into thinking PCI Assessing is simply black and white judgement calls, PCI DSS is complex. In fact, as a security professional, it’s easy to take any good security practice from your brain and tell someone trying to comply with PCI DSS that it needs to be done.  For example, changing passwords on a somewhat regular basis is a practice that we all hate doing, but force our users to do anyway. Even without looking at PCI DSS—a standard that has the word “security” in its name—a QSA could tell someone to set up some kind ...

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Seven Deadly Sins of a QSA (Part 1) standard

Those of you that attended HoustonSecCon or #BSidesDFW, you saw my presentation entitled “The Mistakes QSAs Make.” After presenting, I thought the overall message needed to get to a wider audience and not just the slides I present. I set upon this endeavor and came up with the following series entitled, the Seven Deadly Sins of a QSA. I’m going to be posting this over the next couple of months (and a single PDF in its entirety when I finish) for you guys out in the tubes. Here is a brief intro to get things going! People make mistakes—and in a people business like consulting, you can expect to see more than a few of them. This series explores seven ...

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Herding Cats January, Laws, It’s CHAOS! standard

Have you checked out ISSA Connect yet? The next issue is up there with my column, Laws, It’s CHAOS! The theme for this month is all about legislation. Just like the money supply here in the US, it’s going up in volume at an alarming rate. How do you navigate your way through this soup? I’ve got some tips for you! If you are a member, log into ISSA Connect and join the discussion! Interact with great professionals globally as well as the authors that you enjoy reading every month. If you are not a member, sign up today!

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PCI 2.0 is now Effective! standard

The PCI Security Standards Council announced today that PCI DSS 2.0 is now effective. What does this mean for you as a company that must comply with PCI DSS? First, don’t panic. PCI DSS v1.2.1 is still valid until the end of 2011. If you are working on project plans to finalize compliance against this version, continue to do so, and start working on your PCI 2.0 plans. Your acquirer can provide specific guidance on exactly when you need to send them a validated 2.0 Report on Compliance. Next, you should have a gap analysis done against the new standard—sooner rather than later (I happen to know a team of folks that would be GREAT at this….). While there are ...

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December 2010 Roundup standard

What was popular in December? I was a little bit slow with the posts this month, but I made up for it with two Five Things lists for ya!  December is traditionally a slow month for some, and for vendors like me, it was chaotic. We introduced some new services at EMC and still have been reeling from the PCI v2.0 release. Here are the five most popular posts from last month: PCI DSS 2.0 Release and Review. For the THIRD month in a row, this post took the number 1 spot. This release is two years in the making, and the next one is due in thirty-four months. I threw together a few notes along with links to the ...

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