When Better Security Equals Weaker Compliance
Written by David TaylorGuestView Columnist David Taylor is the Founder of the PCI Knowledge Base, Research Director of the PCI Alliance and a former E-Commerce and Security analyst with Gartner.
Sometimes, security and compliance are totally in sync: When you increase your security, you improve your compliance (with PCI, SOX, HIPAA, etc.). But other times, not so much.
We have run into several different situations where retailers have rejected the use of security controls and reporting tools that would improve both their effective security and their awareness of threats. They turned down these technologies because buying them would have “made” the retailers non-compliant with PCI. Both the real and the perceived issues of this situation must be explained.
PCI has caused thousands of merchants to turn their flat networks into highly segmented networks. They make this change by adding lots of internal firewalls, altering network configurations, etc. All this segmentation increases the need for tools to help manage and even automate the monitoring of firewall rules, which tend to change quite a bit in some organizations. I’ve been in several situations where tools to assist with this process have been rejected by a potential customer, largely because of concern that the tools would show a PCI assessor or acquirer that the customer was not PCI compliant as a result of certain specific changes.
A comparable situation arises when it comes to patch management, for both application patches and mobile-user workstation patches. In each case, there may be a significant time lag before patches are applied. As a result, I have talked to retailers who feel that having more granular detail and more frequent reporting would result in a finding of “non-compliance” if there should be a security breach. Essentially, this seems to be a case of “any data you collect will be used as evidence against you.”
Everyone knows that external and internal scanning results are highly variable. Most retailers try several different options, often switching ASVs (approve scanning vendors) every year. Many larger retailers tell me they scan far more often than PCI mandates. On the other hand, I’ve talked to some retailers and ASVs who say that there’s a preference for “less granular” reporting. They also say that other options during the setup will result in more positive results, especially when done by an ASV. Some merchants argue that they are not choosing to be less secure. Rather, they are simply “managing” the compliance reporting process. They choose to do more thorough scans on their own after the ASV or the QSA has left.
Many other examples from our research make the same point: Forcing 100 percent compliance with the PCI standards results in actions that run counter to good data security principles. But who is at fault? Mandating 100 percent compliance with PCI is designed to enforce a “balanced” set of controls, so there is not too much reliance on any one (e.g., access controls, network firewalls or encryption). The fact that some merchants take “extraordinary” measures to achieve compliance, even at the expense of security, is either an unintended consequence of the 100 percent compliance requirement or a result of some retailers’ negative experiences dealing with inconsistent interpretation of PCI standards (by the merchant or by a QSA). A third option is that some merchants are trying to save money and effort. They believe that their risks of a breach are low and that the chances their decision to opt for less granular reporting will come back to haunt them are slim.
There is virtually no justification for avoiding more granular reporting and/or control automation. I’ve spoken with several QSAs who are members of our Panel of Experts about this topic. None of them is aware of any instance where a company implemented automated compliance reporting and management tools and then had this data later used against it to prove non-compliance. However, none of these experts was familiar with how such data has been used in court as part of post-breach litigation. Predicting what a court of law could do with this data is always risky. However, I would maintain that implementing controls automation is clear evidence of a merchant’s commitment to understanding and managing the security of its enterprise on a continuous basis.
If you’d like to review our research on this topic, or any other topic related to security and compliance, please visit the
PCI Knowledge Base. If you’d like to participate in our research, please send an E-mail to David.Taylor@KnowPCI.com.
Cards issued by European banks when used online cross border don't usually support AVS checks. So, when a European card is used with a billing address that's in the US, an ecom merchant wouldn't necessarily know that the shipping zip code doesn't match the billing code.
-Marc
