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II. Data flows and systems<br />

Create a data flow diagram that documents<br />

w<strong>here</strong> payment card numbers are stored,<br />

processed and transmitted. From the PCI<br />

Data <strong>Security</strong> Standard, diagrams should detail<br />

physical and logical data flows, “including<br />

transmission and processing of card data,<br />

authorization, capture, settlement, chargeback<br />

and other flows as applicable” (bit.ly/b7di9). As<br />

a best practice, scan for payment card data<br />

outside the PCI environment at least annually.<br />

Next, establish an inventory to document the<br />

systems, applications and databases associated<br />

with each PCI environment. Include details<br />

such as information owner, data custodians,<br />

application managers, PCI network scans<br />

and when the last application assessment was<br />

conducted.<br />

Card Brand Comments Regular Expression<br />

Visa All Visa card numbers start with a 4. ^4[0-9]{12}(?:[0-9]{3})?$<br />

MasterCard All MasterCard card numbers start with numbers 51<br />

through 55.<br />

^5[1-5][0-9]{14}$<br />

American Express American Express card numbers start with a 34 or 37. ^3[47][0-9]{13}$<br />

Discover Discover card numbers start with 6011 or 65. ^6(?:011|5[0-9]{2})[0-9]{12}$<br />

III. Risk and control assessments<br />

PCI requirement 12.1.2 includes an annual<br />

process that identifies threats, and vulnerabilities,<br />

and results in a formal risk assessment.<br />

To identify threats and vulnerabilities, subscribe<br />

to US CERT advisories, the DHS daily<br />

cyber report and vendor security alerts. Merchants<br />

can obtain the Visa list of vulnerable<br />

applications from their acquiring bank. Information<br />

security professionals should join the<br />

U.S. Secret Service Electronic Crimes Task<br />

Force and FBI InfraGard. ECTF and InfraGard<br />

are free and provide threat and vulnerability<br />

advisories.<br />

The scope of a PCI risk assessment is the<br />

same as that of a PCI assessment. Follow the<br />

flow of payment card data in production and<br />

disaster recovery environments and evaluate<br />

compensating controls. Conduct a thorough<br />

risk assessment before implementing new<br />

technologies such as virtualization or cloud<br />

computing.<br />

Conceptualize data flow as a pipe with holes<br />

in it. Areas of vulnerability include systems between<br />

encrypted network connections and the<br />

System<br />

Component<br />

Potential<br />

Failure Mode<br />

Potential<br />

Effect(s) of<br />

Failure<br />

Source: PCI <strong>Security</strong> Standards Council.<br />

Severity<br />

Potential<br />

Cause(s) of<br />

Failure<br />

data flow channel itself such as application<br />

security attacks that easily pass infrastructure<br />

security controls.<br />

IV. Failure Mode and Effects Analysis<br />

Failure Mode and Effects Analysis (FMEA) is a<br />

method used to evaluate potential failures<br />

within a process or system. Analysis includes<br />

consideration of failure severity, rate of occurrence<br />

and detection. FMEA was introduced in<br />

the 1940s by the US Armed Forces. Later, it<br />

was adopted by NASA, the Ford Motor Company<br />

and most recently, Six Sigma<br />

(bit.ly/KZvHY).<br />

FMEA is also a practical way to conduct a<br />

technical risk assessment (bit.ly/cD80M2).<br />

Depending on the size and complexity of the<br />

environment, it will take between eight and<br />

sixteen hours to conduct an FMEA evaluation.<br />

In large organizations, maintenance of controls<br />

may be assigned to several teams.<br />

FMEA participants should include representatives<br />

from physical security, system and network<br />

administration, application development,<br />

information security and operations.<br />

Occurrence<br />

Current<br />

Process<br />

Controls<br />

Detection<br />

www.insecuremag.com 45<br />

RPN

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