Re: Compliance Is Wasted Money, Study Finds

[Tracy Reed <treed () ultraviolet org>]

On Wed, Apr 07, 2010 at 12:43:47PM -0400, Valdis.Kletnieks () vt edu spake thusly:
> I think the issue is a bit deeper than that - the way most regulations are
> drafted, they do *not* force entities to do what they should have done in
> the first place.
>
> What they *do* force is implementing a checkbox.

I have been doing a lot of PCI work in recent years. It isn't
government regulation (although it is often acquiring bank/card brand
regulation) and serves a similar purpose subject to similar
criticisms.

How would you draft regulations such that they do not force them into
implementing a checkbox? I am actually somewhat impressed with the PCI
guidelines. They provide the ability to have "compensating
controls". So if you can adequately explain why a particular
requirement does not need to be met to the letter but the data can
instead be secured by some other means (even better than what the
requirement specifies) you can go that route. It is not a free pass or
an "exception" to the requirements. What it does do is prevent you
from having your hands tied in silly ways.

> Whether said checkbox is actually the best solution *for the actual problem*
> is the issue.  I've seen cases where checkbox auditors insisted that a
> certain critical system "absolutely positively *HAD* to have a firewall".

This is where compensating controls come in with PCI. If there is an
even better solution you are free to implement it.

> Now stop for a moment - what is the *reason* for logs being reviewed?
>
> Is it acceptable to *not* review logs if there's a suitable "throw alert
> on exception" mechanism in place?

Yes. Nobody really has a human read every line of every log. I have
some home-grown stuff which filters out exceptional stuff. That is
quite adequate under PCI.

> That's the problem with most of the regulations - they enforce checkboxes,
> not actually dealing with the overall security posture in a sane way.

Maybe SOX or HIPAA are that way but not PCI. If anything the problem
is more likely with the organizations *wanting* a box to check
(because that is easier than actual thinking about the real problem)
than the regs forcing mindless checkboxes.

-- 
Tracy Reed
http://tracyreed.org

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