2011 secure payments summit

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    Chris JohnsonFraud Monitoring & Incident Response

    October 19, 2010

    The Cyber Landscape

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    Infiltration Technical skill required is low Insecure passwords/remote access Lack of firewalls or segmentation Input validation

    Food & Beverage, Retail, and Hospitality targeted Common POS Integrators, Franchises,

    interconnected businesses Shared/default remote access passwords Shared/default internal passwords

    Franchise breaches Aggregate of small exposures Larger investigation scope

    Data Breach Trends

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    Root Causes 3rd party managed payment systems with

    shared/default passwords. Remote access with insecure passwords

    Default or insecure passwords on publicfacing computer systems. Lack of firewalls or incomplete

    segmentation from non-paymentenvironments.

    SQL Injection / xp_cmdshell

    Card-Present Data Breach

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    Common POS Integrators/Franchises

    Internet

    Username: POSSYPassword: POSSY

    Username: POSSYPassword: POSSY

    Username: POSSYPassword: POSSY

    Hacker

    POS Integrator

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    Interconnected Franchise

    Username: POSSYPassword: POSSY

    Username: POSSYPassword: POSSY

    Username: POSSYPassword: POSSY

    Hacker

    Corporate

    Internet

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    Data Gathering and Proliferation Sophistication and methodology have increased. Automation

    Internal network reconnaissance Malware distribution Card data harvesting

    Alteration of POS configuration files Encryption of card data Modification of file time stamps Secure deletion of evidence

    Volume of per incident exposure declining PA-DSS Compliant applications dont store track data

    Data Breach Trends

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    Input

    CPU

    Input/Output

    PermaStora

    WorkingStorage

    OutputNetworkKeyboard Monitor

    Hard DRAM

    Keylogger NetworkSniffer

    ScreenCapture

    MemoryParser

    FileExfiltration

    Von Neumann and Data Extraction

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    Memory Parsers First seen in 2008 Consisted of separate off the shelf tools

    Memory dumper Track data parser

    Early versions had flaws Caused POS system to run out of disk storage Crashed

    Evolved into stable malware Self-contained application Encrypted track data Modified timestamps of encrypted data Recompiled often to avoid antivirus detection and target

    additional POS systems

    Hotel/lodging and food/beverage franchise industry primarilytargeted

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    Characteristics Shopping Carts With Known Vulnerabilities

    Google Dorks Lack of Input Validation

    SQL injection, Remote File Include,Cross-Site Scripting (XSS), etc.

    Automated tools for input validationvulnerability detection and exploitation

    Card-Not-Present Data Breach

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    SQL Injection

    ErrorCould not convertJohn Doe, 6011 -0000-0000- 0000 to an integer

    Username:

    Password:

    Submit

    or 1=cast((Select cardname, cardnum

    from order where orderid > 0) AS int) --

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    Emerging Attacks and Predictions

    Merchant Credential Theft Fraudulent credits to debit accounts

    Mass SQL Injection

    Large scale automation of SQLInjection

    Cardholder System Infections

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    ?

    Questions

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    Social Media & Your Compliance

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    Speaker

    Bill Uptmore CISSP, CISAEMC Practice [email protected]

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    Social Media & Your Compliance Risk to Compliance

    What Happens? Challenges

    Common Issues How to limit exposure

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    Risk To Compliance Statement of the Federal Trade Commission's Bureau of

    CompetitionOn Guidelines for Merger Investigations

    http://www.ftc.gov FINRA Provides Guidance Regarding the Reviewand Supervision of Electronic Communications - Also see

    Regulatory Notice 10-06 (2010)

    FDA Prescription Drug Requirements Legal Hold

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    What Happens Your Company & Your Reputation

    Law Suit(s) Fines

    More regulatory scrutiny Someone May Be Held

    Accountable

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    Connecting The Dots

    Employee has good news on potential acquisitionEmployee puts the information on Social Network site (company is not stated)

    Three more employees share acquisition , but no one has stated company name

    All employees work for the same company

    Someone connects the dots. Now what?

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    Challenges Companies are not prepared to

    deal with the fast changes in howtheir employees communicate

    Consumer Demand Lack Of Training

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    Common IssuesRes Gesti StatementMiscommunicationFilter What Filter?

    Statement Taken Out of ContextPeople Will Be People

    Cumulative Impact

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    How Does It Happen?

    We have become too open inwhat we say

    We have become conditioned toshare the moment

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    Information Discovery Social Media Monitoring

    Social Networking Site Could beSubpoenaed

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    How To Limit Exposure Provide Training Security Matters Do Your Diligence

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    Chris JohnsonFraud Monitoring & Incident Response

    October 19, 2010

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    Next Generation FirewallsThreats Have Evolved, But Has Your Firewall?

    Dmitriy AyrapetovProduct Line ManagerSonicWALL

    Quick Quiz Real or Fake?

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    Quick Quiz Real or Fake?

    FAKEREALREALFAKEFAKE

    How does malware get on my

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    How does malware get on mycomputer?

    Application Level Attacks Browser Drive-By Downloads (IE, Firefox, Safari) Application Exploits (Adobe Reader, Sun/Oracle JDK, Flash, Office)

    No or Little User Intervention Required

    Application Level?

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    Application Level? Malware is an economy

    Your infected computer is a resource Ransomware/Keyloggers Your Data Botnets/Spam Your Resources & Liability Fake AV Your Money & Time

    Applications are ubiquitous

    Applications easy to target think ROI!

    http://www.zdnet.com/blog/sestudy-finds-the-average-pri

    renting-a-botn

    the average price for renting a botnet is $67 for 24

    hours, and $9 for hourlyacce

    B I Al d H A Fi ll!

    http://www.zdnet.com/blog/security/study-finds-the-average-price-for-renting-a-botnet/6528http://www.zdnet.com/blog/security/study-finds-the-average-price-for-renting-a-botnet/6528http://www.zdnet.com/blog/security/study-finds-the-average-price-for-renting-a-botnet/6528http://www.zdnet.com/blog/security/study-finds-the-average-price-for-renting-a-botnet/6528http://www.zdnet.com/blog/security/study-finds-the-average-price-for-renting-a-botnet/6528http://www.zdnet.com/blog/security/study-finds-the-average-price-for-renting-a-botnet/6528http://www.zdnet.com/blog/security/study-finds-the-average-price-for-renting-a-botnet/6528http://www.zdnet.com/blog/security/study-finds-the-average-price-for-renting-a-botnet/6528http://www.zdnet.com/blog/security/study-finds-the-average-price-for-renting-a-botnet/6528http://www.zdnet.com/blog/security/study-finds-the-average-price-for-renting-a-botnet/6528http://www.zdnet.com/blog/security/study-finds-the-average-price-for-renting-a-botnet/6528http://www.zdnet.com/blog/security/study-finds-the-average-price-for-renting-a-botnet/6528http://www.zdnet.com/blog/security/study-finds-the-average-price-for-renting-a-botnet/6528http://www.zdnet.com/blog/security/study-finds-the-average-price-for-renting-a-botnet/6528http://www.zdnet.com/blog/security/study-finds-the-average-price-for-renting-a-botnet/6528http://www.zdnet.com/blog/security/study-finds-the-average-price-for-renting-a-botnet/6528http://www.zdnet.com/blog/security/study-finds-the-average-price-for-renting-a-botnet/6528
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    But I Already Have A Firewall!Stateful

    Firewall

    80 = HTTP

    443 = HTTPS

    21 = FTP

    3389 =RDP

    Firewall Report -Some Web Traffic, FTP, RDP, HTTPS

    Everythings OK!

    Web TrafficWeb Traffic

    Great What Else? Application Chao

    http://www.ebay.com/http://www.ebay.com/
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    GreatWhat Else?

    Bad Control Good Prioritiz

    Applications tunneling througha few ports

    Many, many applications

    Traditional BW Managementcant keep up

    Full ApplicCo

    SSL TInspec

    Content Secu

    Application Chao

    Evolution of Firewalls

    http://www.oracle.com/index.htmlhttp://en.wikipedia.org/wiki/Image:Skype_logo.pnghttp://images.google.com/imgres?imgurl=http://www.experientia.com/blog/uploads/2007/08/sap.jpg&imgrefurl=http://www.experientia.com/blog/sap-user-experience-testing/&h=1188&w=2395&sz=205&hl=en&start=6&um=1&tbnid=TgxjctreCJb-NM:&tbnh=74&tbnw=150&prev=/images?q=sap&um=1&hl=en&sa=Nhttp://images.google.com/imgres?imgurl=http://www.instranet.com/company/partners/images/siebel_logo.gif&imgrefurl=http://www.instranet.com/company/partners/&h=60&w=200&sz=2&hl=en&start=1&um=1&tbnid=J7qL057FlT2mkM:&tbnh=31&tbnw=104&prev=/images?q=siebel+logo&um=1&hl=enhttp://www.ebay.com/http://en.wikipedia.org/wiki/Image:BitTorrentLogo.gifhttp://www.salesforce.com/products/
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    CONFIDENTIAL

    Evolution of Firewalls

    Stateful Packet Inspection:UTM:

    Next Generation Firewall:

    Addressing of the EnvelopeContents of the Envelope/Letter

    Subject of the Letter

    Stateful InspectionDeep Packet Inspection (DPI)

    D d

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    Do you ever wonderWhats really on my network?

    Wheres all my bandwidth going?

    Where Is this traffic coming from?

    What are the threats?

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    Visualize??

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    Visualize??

    Application Traffic

    Application BreakdownUser BreakdownCountry Identification

    Dig Deeper with Filtering

    Apply Application Control

    So Again What Does an NGFW Do?

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    So, Again, What Does an NGFW Do? Identify and Control Applications and Users

    Block Intrusions Block Malware and Threats Enforce Content Security

    All of the above, but for SSL traffic as wellt Importantly not hinder performance and LET YOU WORK

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    Q&A

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    Chris JohnsonFraud Monitoring & Incident Response

    October 19, 2010

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    Where Privacy Meets PCI

    Chris ZoladzNavigate LLC

    Events Making PCI/Privacy a

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    g yBusiness Priority

    Consumer and regulator expectationshave never been higher

    State security breach laws result in privacy lapsesbeing public events

    The Massachusetts privacy law could be a gamechanger

    U.S. federal privacy law is likely

    U S State Security Breach Laws

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    U.S. State Security Breach Laws46 States including the District of Columbia have a breach law

    The laws are similar but not the same, differences include:

    Definition of a breachInclusions and exceptions

    Definition of PIINotification Requirements

    Learn Morehttp://www.ncsl.org/IssuesResearch/TelecommunicationsInformationTechnology/ SecurityBreachNotificationLaws/tabid/13489/Default.aspx

    The Maryland Law

    http://www.ncsl.org/IssuesResearch/TelecommunicationsInformationTechnology/SecurityBreachNotificationLaws/tabid/13489/Default.aspxhttp://www.ncsl.org/IssuesResearch/TelecommunicationsInformationTechnology/SecurityBreachNotificationLaws/tabid/13489/Default.aspxhttp://www.ncsl.org/IssuesResearch/TelecommunicationsInformationTechnology/SecurityBreachNotificationLaws/tabid/13489/Default.aspxhttp://www.ncsl.org/IssuesResearch/TelecommunicationsInformationTechnology/SecurityBreachNotificationLaws/tabid/13489/Default.aspx
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    The Maryland LawCovers both paper and electronic data

    Name in combination with social security numberor drivers license number or credit card number

    Notification exemption if data is encrypted

    State Attorney General must be notified beforeany notifications to Maryland residents are sent

    Notification Content & Requirements

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    Notification Content & RequirementsExplain what happened, why, and how the person canprotect themselves

    De facto practice is to offer 1 year of free creditmonitoring service

    Sent to all affected individuals or communicated to majormedia if individual notification is not practical

    Certain State Attorneys General (e.g., MA, MD, NC) andConsumer Protection Offices must be notified

    Notification Content & Requirements

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    Notification Content & RequirementsSending notification letters

    Credit monitoring serviceCall center to handle questions

    Legal fees

    Lost productivity of employees that are part of the incidentresponse effort

    Potential FTC settlements

    Loss of customer, public and regulator trust

    Recently released Ponemon Institute study disclosed cost of $216per record

    Massachusetts In Detail

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    Massachusetts In Detail

    Written Information Security Program(WISP)

    Designated program owners

    Employee training

    Policies

    possession of PII outside the facility

    remote access to PII

    disciplinary actions for violations

    Inventory paper and electronic records as wellas systems and media

    Regularly monitor and annually review securimeasures

    Encrypt PII on laptops, portable devices

    Service provider program

    Limit the collection, storage and access to PIIRisk assessments

    Incident response

    Specific computer security requirements

    Learn Morehttp: //www.mass.gov/?pageID=ocahomepage&L=1&L0=Home&sid=Eoca

    The FTC is Also an Enforcer

    http://www.oispp.ca.gov/default.asphttp://www.oispp.ca.gov/default.asphttp://www.oispp.ca.gov/default.asphttp://www.oispp.ca.gov/default.asphttp://www.oispp.ca.gov/default.asphttp://www.oispp.ca.gov/default.asphttp://www.oispp.ca.gov/default.asp
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    The FTC is Also an EnforcerPrivacy is a central element of the FTCs consumer

    protection mission. (Source: www.ftc.gov/privacy)

    Focuses on unfair or deceptive trade practices

    Settlements:- Range from tens of thousands to millions of dollars.- Include agreement by the company to independentoversight of their information security program for up toyears.

    EU Data Protection Directive

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    EU Data Protection Directive Went into effect in 1998

    Key requirements:- Notice- Choice- Onward transfer- Security- Data Integrity- Access- Enforcement

    (Note: Canada, Australia, Russia and others havesimilar national laws)

    Dont Think If, Think When

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    Don t Think If, Think When Incident response planning

    Learn from others - was their weaknessyour weakness?http://www.privacyrights.org/ar/ChronDataBreaches.htm

    You cant plan for every scenario but youcan plan many of them

    An effective plan is the difference betweena well-managed event and a disaster.

    Elements of an Incident Responsel

    http://www.privacyrights.org/ar/ChronDataBreaches.htmhttp://www.privacyrights.org/ar/ChronDataBreaches.htmhttp://www.privacyrights.org/ar/ChronDataBreaches.htmhttp://www.privacyrights.org/ar/ChronDataBreaches.htm
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    pPlan

    Form a Response Team

    Incident Discovery and ConfirmationIsolate and RemediateNotificationAnalysis/Explanation

    Close-outPractice the planExecute with speedThe plan should be viewed by legal counsel

    Are You Prepared?

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    Are You Prepared?A person calls the IT Director on Monday morning, theheaviest online sales day of the week and:

    Claims to have penetrated the companys websitethrough a common vulnerability and is recordingevery keystroke entered on the website.

    Provides the last 10 ten credit card numbers enteredon the website as evidence.

    Is requesting a $50,000 consulting fee to help thecompany strengthen its website security

    Provided a bank account and routing number for awire transfer.. . .

    Initial Questions

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    QWhat would you do first?

    What if the callers information regarding the last 10transactions is accurate?

    Has the website really been compromised or is thecaller receiving data from an employee?

    Would you shut down the website?

    Would you immediately call law enforcement for thisapparent extortion?

    . . .

    Contact Information

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    Chris Zoladz

    [email protected]

    The PCI Coach

    www.thepcicoach.com

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    Chris JohnsonFraud Monitoring & Incident Response

    October 19, 2010

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    Payment Application DataSecurity Standards

    Unraveling the Mystery of PA DSS

    What is PA DSS

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    The global security standard created by the Payment CardIndustry Security Standards Council (PCI SSC).

    Is the definitive data standard for software vendors thatdevelop payment applications.

    Prevents developed payment applications for third partiesfrom storing prohibited secure data including magnetic stripe,

    CVV2, or PIN

    Requires that software vendors develop paymentapplications that are compliant with the Payment Card

    Industry Data Security Standards (PCI DSS).

    Why PA DSS

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    y Payment Application found source of multiple data

    compromises events

    Merchants has limited insight to the security of commercial payment applications

    Merchants held liable for losses associated with datacompromise events, not application provider

    What is Subject to PA DSS

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    jThe PA-DSS applies to software vendors and others who

    develop payment applications that store, process, or transmit

    cardholder data as part of authorization or settlement, wherethese payment applications are sold, distributed, or licensed tothird parties. Applies to payment applications provided in modules

    May only apply to the baseline module ,if that module is the only one performingpayment funct

    If other modules also perform payment functions, PA-DSS applies to those modules

    as

    Note: It is considered a best practice for software vendors to isolate paymentfunctions into a single or small number of baseline modules, reserving other modules

    for non-payment functio

    What is NOT Subject to PA DSS

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    jMerchants that use in-house developed applications &

    stand-alone POS hardware terminals

    Only applies to applications that store ,process, or transmit cardholder data

    Home grown systems must be included inover all PCI DSS compliance review (DSS

    Req. 6.3) Point to point encryption and tokenization do

    not remove an application from scope

    Terminal may not connect to other systems

    PA DSS MandatesEffective

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    Phase Visa Compliance MandateEffectiveDate

    1

    Newly boarded merchants must not use known vulnerablepayment applications, and VisaNet Processors (VNPs) and agents

    must not certify new payment applications to their platformsthat are known vulnerable payment applications

    1/1/08

    2 VNPs and agents must only certify new payment applications totheir platforms that are PA-DSS-compliant

    7/1/08

    3Newly boarded Level 3 and 4 merchants must be PCI DSScompliant or use PA-DSS-compliant applications*

    10/1/08

    4VNPs and agents must decertify all vulnerable paymentapplications**

    10/1/09

    5Acquirers must ensure their merchants, VNPs and agents useonly PA-DSS compliant applications

    7/1/10

    PA DSS Mandates - Continued

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    Effective July 1, 2012 , MasterCard will revise the MasterCardSDP Program Standards to require all merchants and Service

    Providers that use third party-provided payment applications toonly use those applications that are compliant with the PaymentCard Industry Payment Application Data Security Standard (PCIPA-DSS), as applicable. The applicability of the PCI PA-DSS tothird party-provided payment applications is defined in the PCI

    PA-DSS Program Guide. In addition, MasterCard will establish anew PA-DSS compliance validation requirement for Level 1,

    Level 2, and Level 3 merchants as well as Level 1 and Level 2Service Providers.

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    R l i d D l i

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    Regulation and Deregulation :

    How Compliance Gets Made

    Michael DahnDirector, PCI Compliance

    Rules Keep Getting Bigger

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    Hello Dave 2001 : Space Odyssey

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    Know the Rules Before You CanBreak Them

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    Break Them

    Dance Improvisation Music Composition Know which rules are

    Followed Flexible Broken

    Why Regulation?

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    Trying to get a

    handle on largeproblems: Unbound risk

    Consumerprotection

    How Compliance Happens

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    Data Breaches & Black Swans

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    Slide Title

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    Large Data Breaches (million records)

    Evolution of Methods Flat files, network sniffing, serial port sniffing, custommalware

    EU: retail moved to e-commerce

    What risk are we trying to prevent?

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    Next Steps

    Vaccinations & RegulatoryCompliance

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    p The problem is that although most all agree that

    vaccination is positive for the population not everyoneagrees that it is positive for the individual

    Individuals say: My environment is already secure I know how to manage risk better than the regulatory

    bodies

    My environment is special and unique and does not fitinto your Procrustean boxes

    Are we as secure as we think we are? Do we rely on third parties? Who do we share data with?

    Who do we give access to our data and systems?

    Vaccinations & RegulatoryCompliance

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    p Economics of Immunization and

    Compliance A poorer population will benefit more strongly

    from an immunization program than one thatmaintains a high level of sanitation, healthcare, and treatment programs

    A more vulnerable population (e.g. retail,restaurants, higher education, e-commerce,etc.) will benefit more from regulatorycompliance than one that is more highly secure

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    Vaccinations & RegulatoryCompliance

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    p Tipping point of vaccination

    An aggressive vaccination program thatfirst targets children and ultimatelyreaches 70% of the US population wouldmitigate pandemic influenza *flu+

    Vaccine and Infectious Disease Institute(VIDI) at Fred Hutchinson CancerResearch Center

    So what makes us happy?

    Slide Title

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    Bullets

    Bullets Bullets Bullets

    Bullets Bullets Bullets

    Slide Title

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    Bullets

    Bullets Bullets Bullets

    Bullets Bullets Bullets

    Understand the Intent

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    Do not focus on the fingeror you will miss all thatheavenly glory [of RegulatoCompliance+

    - Bruce Lee, Enter the Dragon

    Example: Audit Logging

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    PCI DSS Requirements

    # 10.2 and the implications Intent

    This is only the beginning

    Verizon PCI Compliance ReportA ll l i ll

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    Are all regulatory requirements equallyimportant?

    What are organizations good/bad atdoing?

    How does regulatory adherence impactdata breaches?

    How effective is regulatory compliance?

    Compliance vs Validation

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    21

    A point-in-time event

    Validation

    In order to understand the report and the conclusions drawn from the data,it is necessary to differentiate between c ompliance and v alidation .

    6

    A continuous process of adheringto the regulatory standard as setforth in the PCI DSS

    Compliance

    Compliance Statistics

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    What are we bad at doing?

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    % of Orgs meeting PCI Regs

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    Slide TitleB ll t

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    Bullets

    Bullets Bullets Bullets

    Bullets Bullets Bullets

    3 Habits of Highly Effective Regulation Education Education Education!

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    Education, Education, Education!

    Drives adoption and adherence

    Flexibility of controls

    100 % compliance is not the goal when system failures occur groups

    PCI DSS Compensating controls EU Data Protection Directive Comply or explain

    More data for Risk Modeling

    Can we ever manage risk on a moving target? Frequentist vs. Bayesian statistics

    What is the Solution? Building more roads to ease traffic is like

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    Building more roads to ease traffic is liketrying to cure obesity by loosening the belt

    Richard Moe, Head of the US National Trust foHistoric Preservation

    Simply applying more security does not

    necessarily mean you achieve bettersecurity

    Rotate days that cars are permitted on theroad?

    What is the Solution?H l t d t l

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    Help prevent data sprawl

    Security is required where data is maintaine Data, data, anywhere? Data, data, everywhere?

    Reduce scope through grouping of systems

    Business Process Re-engineering The more complex a system the harder (and

    more costly) it is to maintain

    Options Examine Use Cases

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    Examine Use Cases Medical record data vs. payment card data Data retention sometimes required, but what

    do you retain? Dept collection agencies Reoccurring payments

    Data mining and analysis Cost to secure data vs. Business need for

    data Cost to securing data can be proportional to

    the volume of it

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    Questions: @MikD

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    Chris JohnsonFraud Monitoring & Incident Response

    October 19, 2010

    Compliance Validation Overview

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    Dick BlossFifth Third Processing Solutions

    Vice PresidentGovernance, Risk and Compliance

    Where Do We Begin? Understand the mission and scope

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    Understand the mission and scope

    Appoint a program manager Discuss with acquirer Engage your security org. & others Determine a schedule

    BE OBJECTIVE

    The Players PCI Security Standards Council

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    PCI Security Standards Council

    The Networks (The Brands) Your Acquirer Your third-party providers Every employee of your company

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    Qualified Security Assessors Willing to partner

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    Willing to partner

    Consultative Insightful

    Resourceful

    Available Communicative

    Scope - Less is More Segment your network

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    Segment your network

    Retain only the data you need Limit access by non-essential

    systems to cardholder data region

    Talk to acquirer & providers aboutP2P encryption and tokenization

    Validation TipsAIM and DO

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    Awareness and Attitude Inventory Monitoring

    Documentation Organization

    Monitoring Vulnerability Scans

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    Vulnerability Scans

    Approved Scanning Vendor Quarterly doesnt mean JUST quarterly

    Penetration Tests

    Event Logs File Integrity Providers Compliant Status

    Assertions of ComplianceQSA/Merchant confirms that ...

    ROC was completed according to the PCI DSS Requirements

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    ROC was completed according to the PCI DSS Requirements

    Its all true! (Fair representation in all material aspects)

    Their payment application stores no sensitive data after the authn

    That they have read the PCI DSS and maintain 24/365 compliance

    they found no evidence of storage of magnetic stripe or PIN data

    And the Return on This Effort?

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    ValidationCompliance

    Security

    A point-in- timeevent

    You oother 364

    A long

    Leverage Available Resources Acquirer may offer

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    q y

    Training Step-by-step SAQ guidance Advice on security best-practices

    PCI Security Standards Council www.pcisecuritystandards.org/merchants Annual Community Meetings

    Brands and their web sites

    Challenge Your Providers PTS & PA-DSS compliant products?

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    Providers compliant status and ownershipof responsibility? Is your acquirer responsive and providingdirection?

    Do you have clear instructions on properconfiguration of your paymentapplications?

    Do you really need that card number?

    Questions?

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    Chris JohnsonFraud Monitoring & Incident Response

    October 19, 2010