Security Basics mailing list archives
RE: [Full-disclosure] Compliance Is Wasted Money, Study Finds
From: "Lyal Collins" <lyalc () swiftdsl com au>
Date: Sat, 24 Apr 2010 14:37:15 +1000
I'd like to jump into this exchange of views for a moment. As a QSA, I know PCI DSS is not perfect. Its certainly better that ISO 27001/2 imho, where you decide what you want assessed against criteria you define. HIPAA, SOC and GLBA et al are virtually non-existent apply in my country, so 27001 is one viable yardstick for this international discussion. I know one bank that had 27001 compliance years ago - they simply defined the target as the 6 person IT security team, not the 35,000 employees across 1000+ locations and 300+ systems. Outcome = tick in the box, great publicity, and no actual changes to their security posture. However, PCI doesn't let you get a tick in a box by allowing you to choose which things to assess - its all or nothing. Compared to the security status of a site prior to a PCI review, PCI is pushing virtually all companies miles ahead in their security posture. Of the 12 compliance areas in PCI DSS, virtually all the sites I, and my colleagues see are mostly complaint to 1 or 2 (anti-virus, and encrypted transmission over external networks). Out of the 230+ individual PCI DSS requirements, 30% is an average score prior to a company starting PCI compliance activities. They'd be in the same situation when measured against any 'good security practice' criteria. Some examples, minor variations of which emerge in every new site: - Watching 3 people in a room argue about the actual network layout, because there is no network diagram that is remotely accurate or less than 2 years old, and the details are all in 1 or 2 person's heads, is scary - they have no idea of network assets - and these are in sites with under 100 employees. - Finding firewall rules that include 'any any' because that's what they applied when first setting up the device 3 years ago but forgot to remove is scary - meaning all the subsequent effort on applying specific firewall rules have protected nothing and wasted change management time! - finding that a company 20+ systems with sensitive data, not two as they originally thought is scary - Builds of servers, databases and web app frameworks that are virtually "out of the box" is scary. - Patching that is a 'not at all' situation, or a process that occurs annually or semi-annually at best in many companies. Yet Verizon's report, and similar, show a significant number of successful attacks leveraged holes that are years old. - IPS/IDS, and audit logging, reviewing audit logs - who needs 'e,m - we KNOW we are secure' is a simplified summary of how systems are actually managed. - "We've got a firewall and ant-virus so we are secure' is still a significant part of many site's security posture. - Seeing security policies that literally require a firewall, locked server rooms and a password on workstations is scary. - Seeing developers who insist the production system retains between 3 and 10 copies of every record processed, indefinitely, spread across multiple components and all associated backups, exponentially increases the range of targets an attacker can compromise for gain. - Production systems running NT4, Windows 2000, Solaris 8 and AIX 5.1 ( all in 2009) - scary And these situations are nation wide, and in some cases, multi-national organisations, not a 'business in a garage'. So when PCI demands that aspects are addressed, it is not wasted effort imho - its merely making companies invest in 'average security practice' (no, its not even expecting 'security best practice'). In my personal experience of over 40 sites PCI DSS is a major advance in the security posture of companies, for at least some of their systems, applications and data. Many of these same companies do actually have reasonable security in many other aspects of their systems. Unfortunately, the security gaps are wide, deep and ever present. Its not perfect, its not even applied to a whole enterprise, just selected elements of a business. However, PCI does reduce risks in these selected elements of a business relative to the pre-PCI status quo. Further, when a company absorbs PCI into the 'business as usual' management of IT, it slowly permeates elsewhere, due to budget unlocking, increased awareness, and many infrastructure security controls in PCI overlap into non-PCI parts of the business. Of course, when the company pay 'check in a box' attitudes to information security, then they get 'ticks ina box, not security. Year 2 and 3 PCI assessments of clients shows PCI has either 'stuck' as BAU or means repeated remediation effort. Treating any form of compliance as a tick in a box invariably means a low cost to benefit outcome in my experience. PCI is not always cheap. The reality I've experienced over 5 years of PCI is that companies have under invested in people, processes and in some cases, security products in some (occasionally all) areas of their business. As indicated above, some security compliance programs do appear to provide little or no real security improvement - FISMA, for example, based on press reports. Your mileage may vary. PCI DSS is one compliance program making measurable, significant improvements to the protection and security management of selected information and systems, imho. Disclaimer - I've cherry picked some examples above, for deliberate effect. However these examples and minor variations are representative examples of the overall state of information security I've seen in companies, prior to them progressing toward PCI compliance. lyalc -----Original Message----- From: full-disclosure-bounces () lists grok org uk [mailto:full-disclosure-bounces () lists grok org uk] On Behalf Of Thor (Hammer of God) Sent: Saturday, 24 April 2010 4:32 AM To: Stephen Mullins Cc: full-disclosure; security-basics () securityfocus com Subject: Re: [Full-disclosure] Compliance Is Wasted Money, Study Finds Three things: 1) I am one of those people, as many of us are. 2) I disagree - compliance with the standard, as put forth by the body developing the standard, certainly implies a real security benefit. Does PCI=Security? No, but it certainly helps. There is a huge difference between "ensure" and "imply." Using them together like that as if they are synonymous is a red herring. Think about what you just said: "it doesn't imply real security." THAT doesn't define ANYTHING actionable. Nothing. What the standard does IS to define at least measures to be taken that can increase security - it has specifics and action items. It is tangible. And, it is far more likely to provide a real benefit than not. It *certainly* does more than having some policy say "You must imply real security." If you are one of those people that care about security, and if your takeaway from PCI is that "it doesn't imply real security" but you fail to tell us what does, then I would have to say you are not really providing any benefit. 3) "Apparently not a cost of doing business" how? What did I say that makes that statement apparent? I fail to see how you can connect what the OP stated as "Compliance is Wasted Money" with "apparently having a secure network is not a cost of doing business." They are two different things. If you want to process credit cards in your business to make more money, and the credit card industry says, up front, "ok, you can play if you follow these rules," then that is a cost of doing business. If you actually do enough business to justify PCI audits, and you as a security person implement a system that passes all PCI audit requirements as written, but still FAIL to have a system where no security is implied, then YOU have not done your job. No amount a blaming PCI's inadequacies is going to make up for people not taking responsibility for doing their jobs. Period. t -----Original Message----- From: Stephen Mullins [mailto:steve.mullins.work () gmail com] Sent: Friday, April 23, 2010 10:40 AM To: Thor (Hammer of God) Cc: Christian Sciberras; security-basics () securityfocus com; full-disclosure Subject: Re: [Full-disclosure] Compliance Is Wasted Money, Study Finds
I don't see what the hubbub is
Some people in the information security industry actually care about securing systems and the information they contain rather than filling in check boxes. Compliance may ensure a minimum standard is met, but it does not ensure or imply that real security is being maintained at an organization. As you say, PCI has become a cost of doing business whereas having a secure network is apparently not a cost of doing business. This is a problem. Crazy notion, I know. On Fri, Apr 23, 2010 at 1:18 PM, Thor (Hammer of God) <Thor () hammerofgod com> wrote:
How can you say it is "wasted"? It doesn't matter if you are a "fan" of it or not, in the same way that it doesn't matter if you are a "fan" of the 4% surcharge retail establishments pay to accept the credit
card as payment.
Using your logic, you would way it is "wasted money," and might bring into question the "value" of the surcharge, etc. It is simply a cost of doing business. If you choose to offload processing to a payment gateway, then that will also incur a cost. Depending on your volume, that cost may or may not be higher than you processing them yourself while complying to standards. The implementation of actual security measures will be different. But you can't "handle" credit cards in the classic sense of the word without complying with PCI. If you pass along the transaction to a gateway, you are not handling it. If you DO handle it, then you have to comply with PCI. If you process less than 1 million transactions a year, you can "self audit." If you process more,
you have to be audit by a PCI auditor.
None of this MEANS you are secure, it means you comply. If you don't like PCI, then don't process credit cards, or come up with your own. I still don't really see what all the hubbub is about here. t From: Christian Sciberras [mailto:uuf6429 () gmail com] Sent: Friday, April 23, 2010 9:29 AM To: Thor (Hammer of God) Cc: Christopher Gilbert; Mike Hale; full-disclosure; security-basics () securityfocus com Subject: Re: [Full-disclosure] Compliance Is Wasted Money, Study Finds it is simply part of the cost of doing business in that market. A.k.a. wasted money. Truth be told, I'm no fan of PCI. Other companies get the same functionality (accept the storage of credit cards) without worrying about PCI/DSS (e.g. through Payment Gateways). In the end, as a service, what do I want, an inventory of credit cards, or a stable payment system? The later I guess. As to security, it totally depends on implementation; one can handle credit cards without the need of standards compliance. My two cents. Regards, Christian Sciberras. On Fri, Apr 23, 2010 at 6:07 PM, Thor (Hammer of God) <Thor () hammerofgod com> wrote: Another thing that I think people fail to keep in mind is that when it comes to PCI, it is part of a contractual agreement between the entity and card facility they are working with. If a business wants to accept credit cards as a means of payment (based on volume) then part of their agreement is that they must undergo compliance to a standard implemented by the industry. I don't know why people get all emotional about it and throw up their hands with all the "this is wasted money" positioning - it's not wasted at all; it is simply part of
the cost of doing business in that market.
t From: full-disclosure-bounces () lists grok org uk [mailto:full-disclosure-bounces () lists grok org uk] On Behalf Of Christopher Gilbert Sent: Thursday, April 22, 2010 4:48 PM To: Mike Hale Cc: full-disclosure; security-basics () securityfocus com Subject: Re: [Full-disclosure] Compliance Is Wasted Money, Study Finds The paper concludes that companies are underinvesting in--or improperly prioritizing--the protection of their secrets. Nowhere does it state that the money spent on compliance is money wasted. On Wed, Apr 21, 2010 at 5:44 PM, Mike Hale <eyeronic.design () gmail com> wrote: I find the findings completely flawed. Am I missing something? _______________________________________________ Full-Disclosure - We believe in it. Charter: http://lists.grok.org.uk/full-disclosure-charter.html Hosted and sponsored by Secunia - http://secunia.com/ _______________________________________________ Full-Disclosure - We believe in it. Charter: http://lists.grok.org.uk/full-disclosure-charter.html Hosted and sponsored by Secunia - http://secunia.com/
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- Re: Compliance Is Wasted Money, Study Finds, (continued)
- Re: Compliance Is Wasted Money, Study Finds Mike Hale (Apr 26)
- Re: [Full-disclosure] Compliance Is Wasted Money, Study Finds Valdis . Kletnieks (Apr 26)
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- Re: [Full-disclosure] Compliance Is Wasted Money, Study Finds Mike Hale (Apr 26)
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- Re: [Full-disclosure] Compliance Is Wasted Money, Study Finds Stephen Mullins (Apr 26)
- Re: [Full-disclosure] Compliance Is Wasted Money, Study Finds Mike Hale (Apr 26)
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- Re: [Full-disclosure] Compliance Is Wasted Money, Study Finds Mike Hale (Apr 26)
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- Re: [Full-disclosure] Compliance Is Wasted Money, Study Finds BMF (Apr 26)
- Re: [Full-disclosure] Compliance Is Wasted Money, Study Finds Michael Holstein (Apr 26)
- RE: [Full-disclosure] Compliance Is Wasted Money, Study Finds Thor (Hammer of God) (Apr 26)
- RE: [Full-disclosure] Compliance Is Wasted Money, Study Finds Lyal Collins (Apr 26)