With the most recent high-profile credit card data breach occurring late last month at Global Payments, one has to question the real benefit of PCI-DSS.
After all, didn't a nationally-recognized Qualified Security Assessor (QSA) confirm their compliance with PCI-DSS? If so, how is it that the company still had a breach?
There are very few details on exactly what happened at Global Payments. One rumor has the breach occurring through a taxi company in New York. Another rumor states the breach involved answering a series of knowledge-based security questions correctly.
The truth is, Global Payments may never know exactly what led to the breach.
Once the breach became public, VISA removed Global Payments from its list of "approved" card processors. VISA indicated the company can be reinstated after an independent assessment of compliance with industry standards.
If we read between the lines, VISA is essentially saying that since Global Payments had a breach, they must not have been in compliance with PCI-DSS standards at the time of the breach.
So where does that leave us regarding PCI compliance?
Basically the same place that any compliance review leaves you. Just because an organization is compliant with a given standard does not mean that bad things won't happen.
Credit card processors have some very valuable information that bad guys all over the world would love to get their hands on. They are the Fort Knox of the modern world. When bad guys are motivated, it seems no amount of security can keep them out. Does that mean PCI-DSS standards are worthless?
Not at all. It just means it isn't foolproof. Especially not in today's world of spear phishing, trojans and highly coordinated social engineering attacks. When you have good locks on your data, the bad guys will simply begin targeting those within the organization that have the keys.
No matter how much technology you throw at security, people will always be the weakest link. The PCI-DSS standard (and many others) doesn't do a very good job of evaluating how well we train our people to recognize social engineering and spear phishing.
As evidence, look at the facts behind the breaches at RSA, Epsilon, and HBGary. Each of those breaches involved a failure of humans to recognize that they were being enticed to hand over the keys. If we ever do get any details about this latest breach at Global Payments, I'm betting there was a component of human failure. It can be difficult to recognize the wolf in sheep's clothing when they are asking for the keys.
PCI-DSS compliance is primarily about setting up and maintaining technology to protect credit card data. With the exception of Requirement 12, the PCI-DSS criteria are predominantly about security technology such as firewalls, intrusion detection, encryption, IDs and passwords, and the like.
Requirement 12: "Maintain a policy that addresses information security for all personnel. A strong security policy sets the security tone for the whole entity and informs personnel what is expected of them. All personnel should be aware of the sensitivity of data and their responsibilities for protecting it." That description does not address the need for a rigorous training program for the human factor.
Are all your employees equally capable of recognizing a spear phishing email? Are they trained how to recognize a telephone-based social engineering exploit? Are they absolutely clear on what information is secret, classified, and public? Without regular ongoing training the human factor will continue to be the weakest link in our security and the bad guys will continue to exploit that weakness.
So what's the answer? First, we have to do a better job with education and training. The SANS Institute has developed a two-day course devoted to "Securing the Human". The course is Management 433.
The intent is to develop and strengthen the human side of the security equation through an effective security awareness program; one that will change behaviors of employees and give them more tools to recognize the wolf in sheep's clothing.
Second, we need to work to improve our standards to include the human factor. That will take time and effort on everyone's part, but especially those at the PCI Security Standards Council and other standards organizations. What have you done recently within your organization to strengthen the "human factor"?