PCI DSS Compliance - Be in Control in Four Moves

The security standard calls for a broad range of security measures, but beyond the use of firewalling, intrusion protection systems and anti-virus software, the understanding of the requirements and responsibilities of the merchant are very often poorly understood.

This guide simplifies the scope of the balance of PCI DSS measures to just four areas.
- File Integrity monitoring
- Event Log centralization
- Security Vulnerability scanning for device hardening
- Change Management process
Understanding and implementing measures to address these four areas will make any QSA happy and get you compliant - and keep you compliant - in no time at all.

File Integrity Monitoring
As a mandated dimension of the PCI DSS, FIM verifies that program and operating system files have not been compromised.

Why is this important? The principal benefit of using FIM technology is to ensure that malicious code has not been embedded within critical application and operating system files. The insertion of a 'backdoor' or Trojan into core program files is one of the more audacious and elegant forms of hacking, and also one of the most dangerous.

The PCI DSS (Payment Card Industry Data Security Standard) specifies the following "Deploy file-integrity monitoring software to alert personnel to unauthorized modification of critical system files, configuration files, or content files; and configure the software to perform critical file comparisons at least weekly" and also that for log files "Use file-integrity monitoring or change-detection software on logs to ensure that existing log data cannot be changed without generating alerts (although new data being added should not cause an alert)".
Contemporary compliance management technology will provide pre-defined templates for all folders and files that should be tracked for File-Integrity, also allowing you to specify additional program folders and files unique to your environment, for instance, your core business applications.

File Integrity Monitoring technology conducts an initial inventory of all filesystems specified and 'fingerprints' all files using secure hashing technology, generating a unique checksum for each file. The system will then audit all files being tracked on a scheduled basis every 24 hours (even though the PCI DSS calls only for weekly checks) with any changes, additions, deletions or modifications being reported to you.
The latest generation of File Integrity Monitoring software also operate in a 'live tracking' mode for ultra-secure environments where file changes are detected and reported in real-time.

Other options to consider are to track and identify actual changes to file contents, useful when tracking configuration files to provide you with a complete audit trail of change history - this can be applied to any form of files such as text and xml.

Continuous Vulnerability Scanning
All security standards and Corporate Governance Compliance Policies such as PCI DSS, GCSx CoCo, SOX (Sarbanes Oxley), NERC CIP, HIPAA, HITECH, ISO27000 and FISMA require Windows and Unix Servers, workstations, and firewalls, routers and switches to be secure in order that they protect and secure confidential data.

'Hardening' a device requires known security 'vulnerabilities' to be eliminated or mitigated. A vulnerability is any weakness or flaw in the software design, implementation or administration of a system that provides a mechanism for a threat to exploit the weakness of a system or process. For the PCI DSS, it is a requirement that all 'within scope' sites are scanned for vulnerabilities every quarter. This gets expensive in a large scale, multi-site estates, as well as being a time-consuming management overhead.

Perhaps the biggest issue is that the results of any scan are only accurate at the time of the scan - any configuration changes made after the scan could render devices vulnerable and in a worst case scenario, devices could be left vulnerable to attack for a 3 month period. The ideal solution is to continuously track configuration changes. This is the only real way to guarantee the security of your IT estate is maintained. Using continuous configuration tracking technology allows you at any time to see the Compliance Score of any server and which settings need to be changed to re-harden the config. Any changes made should be reported, including Planned Changes which should also be reconciled with the original Request For Change or RFC record.

Secure, Centralized Event Log Management
Log analysis is a key weapon in the fight against any cyberattack. By gathering logs from all unix and windows servers, applications and databases, firewalls and routers, the method and pattern of an attack can be understood. Identifying the method and source of any attack allows preventative measures to be continually improved. This is why all security policies place log retention at their core. PCI DSS compliance requires logs to be gathered and reviewed daily, and retained for at least one year. Similarly for GCSx Code of Connection or CoCo compliance - Audit logs recording user activities, exceptions and information security events are to be retained for at least 6 months.

For any compliance initiative, it will be necessary to gather logs from all
- Network Devices
- Windows, Unix and Linux servers
- Firewall or IPS and IDS devices, Email and Web Servers
- Database and Application servers - even IBM Mainframes
- All other potentially useful sources of log information

Although the scope of most compliance standards will be largely satisfied at this stage, far greater value can be extracted from Centralizing Event Logs. Contemporary event and audit log management technology ensures all event logs are analyzed and correlated automatically, applying a comprehensive series of rules pertinent to any Security or Governance policy. Any breach of compliance will be alerted immediately allowing pre-emptive action to be taken before a problem arises. The best log management solutions provide pre-defined rules templates, allowing you to be in control of compliance straight out of the box.

The following is a checklist of features available in today's best log management software -
- All Security and Governance Policies supported via pre-packed Compliance Rule Templates
- Real Time Security Warnings i.e. violation of file integrity monitoring rules
- PCI DSS and GCSx Code of Connection supported 'out of the box'
- Web-based Dashboard and integration with Servicedesk as standard
- Powerful, keyword-based Event Log mining across any combination of devices and applications
- Complete solution for all Security Information and Event Management (SIEM) requirements
The latest generation of centralized log server software allows you to focus on true exceptions and important events by masking off the sometimes overwhelming flood of logs. Use the pre-built Compliance Templates and build your own keyword and logic-based correlation rules, allowing you to manage what really matters to your organization from a security and compliance standpoint.

Change and Configuration Management
ITIL Best Practises identify Change Management as one of the key, central processes that should be understood and assimilated into an IT Service Delivery operation. Change Management as a process is intended to ensure that when changes are made, they are first verified as being completely necessary and adding some value to the organization, and if so, that changes are then well planned, documented and clearly communicated to ensure any potential negative impact from the change is understood and eliminated or minimized. The entire experience and knowledge of the enterprise is harnessed and greater efficiencies can be gained from 'one visit' fixes - i.e. a number of required changes can all be delivered during one planned maintenance window. A well maintained Configuration Management Database (CMDB) will often be used as a means of better understanding the 'downstream' effects of changes and or their impact on a number of critical business services.

Crucially for any organization subject to Corporate Governance-driven security standards, changes to any IT system can affect its security. Installing application updates may introduce new vulnerabilities and making any configuration change may also render systems less secure and more prone to a security breach. The latest change and configuration management software tracks all changes to your infrastructure, exposing all unplanned changes and reporting clearly on the intended - and uniquely, the actual outcome - of any planned change. All network device configurations are automatically and securely backed up, with the option to remediate any unauthorized configuration change. Server configurations are tracked against either pre-defined security policies or your own personalized policy, with any deviations highlighted.
And once firewalls, servers, workstations, switches and routers are all in a compliant state, you need to ensure they remain that way. The only way to do this is to automatically verify configuration settings on a regular basis. Why? Because unplanned, undocumented changes will always be made while somebody has the admin rights to do so - legal or otherwise! The configuration change tracking solution will alert you when any unplanned changes are detected as well as keeping an audit trail of planned changes, reconciled with the request for change details.

This provides a unique 'Closed-Loop Change-Management Safety Net' - when changes need to be made to a device it is vital to ensure that changes are approved and documented - we make this easy and straightforward, reconciling all changes made with the RFC or Change Approval record. An open API allows integration with most service/help desks or other change management systems to establish a link between the change approval process and the actual changes that are made.