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PCI Compliance for Retailers from the Cloud Perspective
Looking at individual PCI requirements and how they are addressed from the cloud

One of the key drivers to IT security investment is compliance. Several industries are bound by various mandates that require certain transparencies and security features. They are designed to mitigate aspects of risk including maintaining the sacrosanctity of customer information, financial data and other proprietary information.

One such affected vertical is retail. No matter if you’re Wal-Mart or Nana’s Knitted Kittens, if you store customer information; if you process payments using customer’s credit cards, you are required by law to comply with a variety of security standards. Although there are several auditing agencies and mandating bodies, today we will concentrate on the one compliance agency that is typically applicable to every retailer-PCI.

PCI (Payment Card Industry) enforces Data Security Standards that looks to ensure that ALL companies that process, store or transmit credit card information maintain a secure environment. Now of course, not all merchants are created equal. Nana obviously doesn’t process the volume or the dollar amount of a national or even a high traffic regional retailer. However, this doesn’t let Nana off the hook. Her online shopping cart still needs to be Payment Application DSS validated (PCI compliant). She still is required to pass security audits of her network…just not as often.

But for the sake of this example, let’s assume you are a retailer who processes more than 20,000 transactions a year and the administrative burden of PCI is a real concern. In fact, it is a business necessity to maintain merchant accounts with VISA, American Express and MasterCard. And it is hugely important to keep the confidence of your customers. Fines for non-compliance aside, a breach of your network could cost millions of dollars. And that doesn’t begin to calculate the cost of customer defection through loss of trust.

Most, if not all, retailers have some sort of PCI monitoring in place. However, they are often cumbersome, expensive and resource heavy. Additionally, too many retail organizations don’t employ a compliance officer, much less a dedicated security person. This doesn’t mean these functions aren’t part of someone’s job description. Typically, they are yet another line item in a plethora of competing priorities and mission critical initiatives. In that security can be considered a cost center, the move to simply do the bare minimum to meet compliance is often an attractive alternative. Until now. Until the cloud. More specifically, a holistic enterprise security initiative deployed and managed from the cloud.

So how does cloud-based security/security-as-a-service meet the requirements of PCI while driving down costs, freeing up personnel resources and providing an easy-yet-comprehensive suite of capabilities and functions?

The easiest way to illustrate the potential is to look at the individual PCI requirements and how they are addressed from the cloud:

1. Protect Data: A cloud-based SIEM offering can accomplish the most important feature of this requirement: the ability to instantly recognize any change, intrusion or activity to your firewall IN REAL TIME. That’s the key. There isn’t the lag of looking at all the logs a week later when the damage has been done, or not being able to tell a suspicious action from a white noise false positive. Whereas many SIEM products can do just this, ones from the cloud provide the additional benefit of 7/24/365 monitoring across the entire enterprise. And, you get a scope of visibility of Fortune 500 class protection for literally pennies on the dollar.

2. No vendor-supplied defaults for system passwords and other security parameters: This process is typically enforced by an identity management protocol. The system includes a password management and synchronization feature. The overarching benefit here is SIEM and identity management are two separate functions from two separate applications. However, applying a holistic solution from the cloud gives you the additional flexibility to recognize new accounts, check device configurations and know when and where configurations have deviated from your standards including the entry of too many incorrect passwords

3. Protect cardholder data: Not only are you required to protect and store data, but ensure encryption of any transmission of that data across public networks. The application of situational awareness is  an effective means of capturing, encrypting and storing (and destroying) certain pieces of information and then providing the auditing regulatory agency with proof that your best practices are in line with internal and external policies. This is the heart of your security and should be treated as such. For instance an immediate alert can be escalated if anyone pings the server in which your data is stored and you can instantly move to block them out or allow access depending on their internally designed permissions.

4. Maintain a Vulnerability Management Program: This includes securing SaaS applications and regularly updating anti-virus software. Again the answer is in the clouds. Single sign on and web authentication can tie together all the permissible applications and provide user provisioning. What makes this especially valuable in the cloud is the speed in which connectors can be created and distributed to only those who require the application. For instance, shipping doesn’t need to see the HR applications and marketing doesn’t require access to inventory programs.

5. Implement strong access control methods: As PCI specifically says access to personal and sensitive data is on a “Business need to know,” cloud-based identity managementprovides control and creates specific provisioning on who can see what and have access to which data. It gives you the visibility and the audit reports to show who accessed what, when and from what device.  Again, the cloud version of this solution ties it together with all the other security solutions giving it true enterprise context.

6. Collect logs and applications impacted by PCI: Log management is one of the most time intensive aspects of security. Not only do the logs need to be collected, but they also need to be studied for traffic patterns, suspicious anomalies, improper or failed access and create an audit trail for card processing systems. An automated system can only do so much and most organizations don’t spend a great deal of man hours scouring millions of lines of machine code. That’s where log management from the cloud is a huge time and asset saver. Not only does it have the automation to review and categorize this code, but security-as-a-service provides the additional human expertise to piece together the situational awareness from multiple silos to give a true report of the security of the enterprise. It’s like having an expert analyst on staff without the associated costs. And of course, those logs can be archived in accordance with PCI requirements for 1 year.

PCI is just one agency with its strict set of requirements. Now imagine the cost and personnel savings  when having to comply with multiple agencies. A VP of Ops from a nationally recognized retail company told me he deals with six agencies on a regular basis. Without a holistic and centralized security approach, he would waste endless hours through redundant reporting. With the application of security centralization, 75 hours per month becomes 10. And more importantly, the degree of accuracy of the reporting is significantly better.

In the above six line items, I described four or five different solutions. That in itself can be a heavy investment...unless you look at layering in the cloud. If you are inclined, there is a growing best practice platform of unified security whereby a company can achieve all these goals by leveraging all the solutions into one single source managed from the cloud (cost-effective, enterprise-powered and compliance -ready). But, that is enough ammunition for several other blogs...so keep posted.

So if compliance is one of your banes of business, maybe it’s time you took a deeper look at the cloud.

Kevin Nikkhoo
Always PCI compliant! (HIPAA compliant too. And CIP, and SOX, GLBA and many, many others!)
www.CloudAccess.com

About Kevin Nikkhoo
With more than 32 years of experience in information technology, and an extensive and successful entrepreneurial background, Kevin Nikkhoo is the CEO of the dynamic security-as-a-service startup Cloud Access. CloudAccess is at the forefront of the latest evolution of IT asset protection--the cloud.

Kevin holds a Bachelor of Science in Computer Engineering from McGill University, Master of Computer Engineering at California State University, Los Angeles, and an MBA from the University of Southern California with emphasis in entrepreneurial studies.

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