PCI DSS: The Next GenerationWritten by Walter Conway
A 403 Labs QSA, PCI Columnist Walt Conway has worked in payments and technology for more than 30 years, 10 of them with Visa.
PCI DSS is going through a generational change. That change has nothing to do with the upcoming release of PCI DSS version 3.0 this fall. Instead, the generational change is in the security professionals I work with everyday, the people who are managing their organizations’ PCI compliance. Most of these professionals are very qualified, but they are new to their job and often also new to PCI.
One result of this generational change is that I am being asked some of the same questions I was asked five or more years ago. The questions range from whether pre-authorization data is in scope (treat it like it is) to the feasibility of E-mailing card data (a seriously bad idea) to what constitutes effective network segmentation (think “air gap”). Fresh perspectives are always welcome, so the implications of this generational change for merchants and QSAs alike are generally positive. But with new compliance staff and assessors come fresh challenges and approaches that can impact every merchant and service provider.
With the release of PCI DSS version 3.0 this fall, the standard will be about seven years old by my calculation. Seven years is a lifetime—or maybe a couple of lifetimes—in the world of technology and data security. A great example of this fact is the PCI Scoping presentation the PCI Security Standards Council staff made at the recently completed RSA Conference.
The PCI Council’s presentation was very good. But to someone who has been in the PCI trenches from the beginning, it didn’t break much new ground. As it turns out, the presentation didn’t have to. The scoping principles described differed little from what could have been presented anytime in the past few years. What was new was hearing some of the same questions from the audience and in the conference hallways that I first heard in 2006.
That fact tells me more merchants are, or should be, taking a fresh look at their PCI scope and not just accepting what they used the previous year (and may have been defined by the previous PCI team).
Let’s start with network segmentation. The point made in the PCI Council’s presentation was that for PCI purposes, network “segmentation” means “isolation.” That is, if a system or device can initiate a connection into the cardholder data environment (CDE) or receive a connection from the CDE, that system or device is in the merchant’s PCI scope. It does not matter if there is a firewall controlling the access. It doesn’t matter if the connection is only for “a little while.” If a connection is possible, then the network is not segmented for PCI purposes and all the devices are in scope.
A merchant’s next-generation PCI team must consider each year the infrastructure and include systems that provide, for example, antivirus updates, patching and Internet domain name searches. A next-generation PCI team leader may not be aware that this issue of “connected to” was settled long ago and that a firewall—even a properly configured and maintained one—is not sufficient to achieve network segmentation. The result of such a misunderstanding could be incomplete scoping and increased risk of a reputation-damaging and expensive cardholder data breach.