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Wednesday, February 19, 2014

PCI DSS and Security Breaches

By Christian Moldes, Director of Compliance Services

Every time an organization suffers a security breach and cardholder data is compromised, people question the effectiveness of the Payment Card Industry Data Security Standard (PCI DSS). Blaming PCI DSS for the handful of companies that are breached every year shows a lack of understanding of the standard’s role. 

Two major misconceptions are responsible for this.

First, PCI DSS is a compliance standard. An organization can be compliant today and not tomorrow. It can be compliant when an assessment is taking place and noncompliant the minute the assessment is completed.

Unfortunately, some organizations don’t see PCI DSS as a standard that applies to their day-to-day operations; they think of it as a single event that they must pass at all costs. Each year, they desperately prepare for their assessment and struggle to remediate the assessor’s findings before their annual deadline. When they finally receive their attestation, they check out and don’t think about PCI DSS compliance until next year, when the whole process starts again. 

Their information security management system is immature, ad-hoc, perhaps even chaotic, and driven by the threat of losing a certificate or being fined by their processor.

To use an analogy, PCI DSS compliance is not a race to a destination, but how consistently well you drive to that destination. Many organizations accelerate from zero to sixty in seconds, braking abruptly, and starting all over again a month later. The number of security breaches will be reduced as soon as organizations and assessors both understand that a successful compliance program is not a single state, but an ongoing process. As such, an organization that has a mature and repeatable process will be compliant continuously with rare exceptions and not only during the time of the assessment.

Second, in the age of Advanced Persistent Threats (APTs), the challenge for most organizations it is not whether they can successfully prevent an attack from ever occurring, but how quickly they can become aware that a breach has actually occurred.

PCI DSS requirements can be classified into three categories:  

1. Requirements intended to prevent an incident from happening in the first place. 
These requirements include implementing network access controls, configuring systems securely, applying periodic security updates, performing periodic security reviews, developing secure applications, providing security awareness to the staff, and so on. 

2. Requirements designed to detect malicious activities.
These requirements involve implementing solutions such as antivirus software, intrusion detection systems, and file integrity monitoring.


3. Requirements designed to ensure that if a security breach occurs, actions are taken to respond to and contain the security breach, and ensure evidence will exist to identify and prosecute the attackers.


Too many organizations focus their compliance resources on the first group of requirements. They give the second and third groups as little attention as possible. 

This is painfully obvious. According to the Verizon Data Breach Investigation Report (DBIR) and public information available for the most recent company breaches, most organizations become aware of a security breach many weeks or even months after the initial compromise, and only when notified by the payment card brands or law enforcement. This confirms a clear reality. Breached organizations do not have the proper tools and/or qualified staff to monitor their security events and logs. 

Once all the preventive and detective security controls required by PCI DSS have been properly implemented, the only thing left for an organization is to thoroughly monitor logs and events. The goal is to detect anomalies and take any necessary actions as soon as possible.

Having sharp individuals in this role is critical for any organization. The smarter the individuals doing the monitoring are, the less opportunity attackers have to get to your data before they are discovered. 

You cannot avoid getting hacked. Sooner or later, to a greater or lesser degree, it will happen. What you can really do is monitor and investigate continuously.


In PCI DSS compliance, monitoring is where companies are really failing.

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