Companies often demand to know what their peers in a particular vertical market are doing within the realm of information security before making new decisions. “We’re in retail” or “healthcare” or “financial services” they will say, “and we want to do what everyone else in our industry is doing.” Why? The TCP/IP revolution has changed everything, including how vertical markets should be viewed. In the old analog world, you could define yourself by your product or service, but no longer. Today it doesn’t matter if your company sells plastic flowers or insurance — what defines you is your data and how you handle it.
When advising Forrester clients on InfoSec, the first question I ask is, “what compliance mandates are you under?” Like it or not, compliance determines how data is handled and that defines your vertical in our data-driven society. For example, I often say that, “PCI is the world’s largest vertical market.” It is a single global standard that affects more companies than not. You may think you are a hotel and your vertical is hospitality, but if you handle credit cards your real vertical — from a data perspective — is PCI.
Data defines markets. Look at your data, your transactions, and your process, and map them to your compliance initiatives. That will determine your digital — not analog — vertical. Using this measure, you can determine your security baseline and compare yourself to companies who must handle data in the same manner as you to help guide your security decisions.
The PCI Security Standards Council released the summary of changes for the new version of PCI — 2.0. Merchants, you can quit holding your breath as this document is a yawner — as we’ve long suspected it would be. In fact, to call it 2.0 is a real stretch as it seems to be filled — as promised by earlier briefings with the PCI SSC — merely with additional guidance and clarifications. Jeff, over at the PCI Guru, has a great review of the summary doc so I won’t try to duplicate his detailed analysis. The most helpful part of the doc is an acknowledgement that more guidance on virtualization — the one function per server stuff — will finally be addressed.
Suffice it to say, it doesn’t look good for all those DLP vendors looking for Santa Compliance to leave them a little gift under the tree this year. I’ve been hearing hopeful rumors (that I assume start within the bowels of DLP vendor marketing departments) that PCI would require DLP in the next version. Looks like it’s going to be a three year wait to see if Santa will finally stop by their house.
Remember that this is a summary of changes so there’s not that much meat yet. The actual standard will be pre-released early next month with the final standard coming out after the European Community Meeting in October.
Last week I published two research reports on the hottest topic in PCI: Tokenization and Transaction Encryption. Part 1 was an introduction into the topic and Part 2 provided some action items for companies to consider during their evolution of these technologies. Respected security blogger, Martin McKeay, commented on Part 1. Serendipitously, Martin was also in Dallas (where I live) last week and we got an opportunity to chat in person about the report and other security topics.
Martin’s post highlighted several issues that deserve some response. He felt that I, “glossed over several important points people who are considering either technology need to be aware of.” Let me review those items:
Comment: “This is one form of tokenization, but it completely ignores another form of tokenization that’s been on the rise for several years; internal tokenization by the merchant with a (hopefully) highly secure database that acts as a central repository for the merchant’s cardholder data, while the remainder of the card flow stays the same as it is now.”
Even though the iPad is barely birthed, there is already a push to provide payment applications for the device. It's time to pull the emergency brake on this trend. Are these applications PA-DSS certified? Do they have swipe devices with crypto hardware built-in? Has the Pin Entry Device been rigorously tested and meet all the PIN Transaction Security Guidelines? There are so many things consumers should know about the security of these new methods of payments *before* they allow their credit card to be captured by an iPad or iPhone. Is the card's Personal Account Number (PAN) encrypted at the moment it is swiped by the device? Does the device establish an encrypted tunnel to transport the transaction to the payment gateway? Doe the iPad store the PAN? Is that storage encrypted or unencrypted? Does the processor support a tokenization scheme to keep the iPad out of PCI scope? Is the payment app the only thing running on the iPad?