Almost all Payment Card Industry (PCI) breaches over the past year, including the most recent one at Supervalu appear to have the following aspects in common:
- They involved some compromise of Point of Sale (POS) systems.
- The compromise and breaches continued for several weeks or months before being detected.
- The breaches were detected not by the retailer but by some external entity – FBI, the US Secret Service, Payment processor, card brands, issuing bank etc.
- At the time the breach was disclosed, the retailers appear to have had a passing PCI DSS certification.
- PCI has one of the more prescriptive regulations in the form of PCI DSS and PA DSS than any other industry. As a case in point, consider the equivalent regulations for Electronic Health Records systems (EHRs) in the United States – the EHR Certification regulation (PA DSS equivalent) requirements highlighted yellow in this document and the Meaningful Use regulation (PCI DSS equivalent) requirements highlighted green. You will see that the PCI regulations are a lot more comprehensive both in breadth and depth.
- PCI DSS requires merchants and service providers to validate and document their compliance status every year. For the large retailers that have been in the news for the wrong reasons, this probably meant having a external Qualified Security Assessor (QSA) performing a on-site security assessment and providing them with a passing Report on Compliance (ROC) every year.
- As for logging and monitoring requirements that should help with detection of a potential compromise, both PCI DSS (Requirement 10) and PA DSS (Requirement 4) are as detailed as they get in any security framework or regulation I am aware of.
- Even if you think requirement #10 can’t help detect POS malware activity, there is PCI DSS requirement 12.2 that requires a security risk assessment to be performed at least once a year. The risk assessment must consider the current threats and vulnerabilities. Given the constant stream of breaches, one would think that the POS malware threats are accounted for in these risk assessments.
- These large merchants have been around for a while and are supposed to have been PCI DSS compliant for several years. And so, one would think they have appropriate technologies and processes to at least detect a security compromise that results in the scale of breaches they have had.
Anyone that has a reasonable understanding of the current Information Security landscape should know that it is not a matter of “if” but “when” an organization will get compromised. Given this humbling reality, it only makes sense that we must be able to detect a compromise in a “timely” manner and hopefully contain the magnitude of the breach before it gets much worse.
Let’s consider the following aspects as well:
So, what do you think may be the reasons why the retailers or the PCI regulations are not effective in at least detecting the breaches? More importantly, what changes would you suggest, both to the regulations and also to how the retailers plan and execute their security programs? Or perhaps even to how the QSAs perform their assessments in providing passing ROCs to the retailers?
I’m keen to hear your thoughts and comments.