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How Allegiant Air solved its PCI problem and got a whole lot better security culture, too
By: Dana Gardner
Jul. 22, 2016 11:00 AM
The next BriefingsDirect security market transformation discussion explores how airline Allegiant Air solved its payment card industry (PCI) problem -- and got a whole lot better security culture to boot.
When Allegiant needed to quickly manage its compliance around the Payment Card Industry Data Security Standard, it embraced many technologies, including tokenization, but the company also adopted an improved position toward privacy methods in general.
Here to share how security technology can lead to posture maturity -- and then ultimately to cultural transformation with many business benefits -- we're joined by Chris Gullett, Director of Information Assurance at Allegiant Air in Las Vegas. The discussion is moderated by me, Dana Gardner, Principal Analyst at Interarbor Solutions.
Here are some excerpts:
Gardner: Let's begin at a high level. What are the major trends that are driving a need for better privacy and security, particularly when it comes to customer information, and not just for your airline, but for the airline industry in general?
Gullett: The airline industry in general has quite a bit of personally identifiable information (PII). When you think about what you have to go through to get on the plane these days, everything from your whole name, your date of birth, your address, your phone number, your flight itinerary, is all going in the record.
There is lot of information that you would rather not have in the public domain, and the airline has to protect that. In fact, there have been a couple of data breaches involving major airlines with things like frequent-flyer programs. So, we have to look carefully at how we interact with our customers and make sure that data is incredibly safe. We just don't want to take the brand hit that would occur if data leaked out.
Gardner: At the same time, we’re enjoying much better benefits by attaching more data to transactions, to process; we're able to cross organizational boundaries. And so, the user-experience benefits of having more data are huge. We don't want to back off from that, but we do want to be able to make sure that that data is protected.
What are some of the major ways we can recognize the need for better data uses, but keep it protected? Can they be balanced?
Gullett: The airline industry is moving forward on a lot of technology fronts. Some airlines, for example, are using mobile devices to welcome specific customers on board with a complete history of how good a customer they are to that particular airline, so they can provide additional services in the air.
Other airlines are using beaconing [location] technologies, which I think is kind of cool. If you have a mobile app on your phone for the airline and you're transiting through the airport, how cool is it to know where you are and how long it's taking you to get through security. So, the airline might adapt at the gate as to whether there are going to be problems or not in boarding that particular plane.
There are a lot of different data points that are being collected and used now with different airlines handling them in different ways. In any event, the need for privacy is important, especially in the European Union (EU), which has incredibly tight data-privacy protection laws.
Gardner: We've talked about that on this podcast series. Now, the answer isn’t just the old thinking around security, where we'll just wall it off, or we'll use as little data as possible. Instead, we need to have more data in more places -- even down at that mobile edge.
So, as we think about ways to accommodate our need for more data in more places, even everywhere, is there top-level thinking that goes along with being able to make the data private, but also usable?
Gullett: That's the balancing point. Everybody wants their data everywhere. Before, a data center protected data inside the tight little confined, hardened shell you used to have, a perimeter with a firewall, and things like that. But we need data out to the edge where it's actually being consumed; that’s what has to happen these days.
Some airlines are putting consumer PII right in hands of the flight attendant on the plane. At Allegiant, for example, we're using mobile devices to accept credit cards on the plane. We're experimenting with a number of different technologies that fall into a category of Internet of Things (IoT), when you think about them. What they all have in common is that they're outside any possible perimeter.
So, you have to find a way to make every device have its own individual perimeter, and harden the data, harden the device, or some combination of the two.
Gardner: Let's hear more about your particular airline. Tell us about Allegiant Air and what makes it unique in the airline industry.
Gullett: At Allegiant, we're up to 54 consecutive quarters of profit, which is unheard of in the airline industry. The famous phrase about the airline industry is, “How do you become a millionaire? You start with a billion dollars and you buy an airline.”
The profitability of airlines has been much in the news over the last couple of decades, because it's cyclical. Airlines fail, go into bankruptcy, or consolidate. There's been a lot of consolidation in the United States, with United taking on Continental, and Delta taking on Northwest as examples. Southwest taking on AirTran is another. Everybody has been in the game.
Allegiant is kind of off on its own. We've found an interesting niche that has very little direct competition on the routes that we serve, and that is taking vacationers to their favorite vacation destinations.
We connect small- and medium-sized markets -- markets like Kalispell, Montana or Indianapolis, Indiana, a medium-sized city. We'll take them to Florida, Las Vegas, or Los Angeles. We have about 19 vacation destinations now. We have about 115 cities overall. In fact, we serve more cities than Southwest, if you want to get a comparison on the size of the route map. And we're also taking the charter operators to three different countries in the Caribbean.
We have quite a different footprint. That adds up to about $1.3 billion in revenue a year, and from a profitability standpoint, Allegiant is regularly recognized as one of the most profitable airlines in the world.
Gardner: It sounds like most of your passengers, perhaps even all of them, are vacationers, not business travelers. Does that change anything when it comes to user experience, privacy, and data security?
Gullett: It doesn't change anything as far as the need to protect the data, but it puts a greater risk of brand problems concerning data breaches.
Consider the fact that our average customer flies with us once or twice a year. They are, in many cases, flying Allegiant, rather than driving to their vacation destination. Or maybe they're taking a vacation they wouldn't have otherwise because of Allegiant's low prices.
So what you have is “not-frequent travelers.” In fact, that would be kind of a name. If we were going to have a frequent-flyer program it would be the “not-frequent-flyer program,” because vacationing people just don't fly as frequently.
If I'm a business traveler, I am on so-and-so [airline], and they had a breach, I'm going to continue to fly them because I have marvelous status with their frequent-flyer program. Allegiant customers say, “Gee, I'm a little concerned about that and if they have a data breach, I think I'll drive instead.”
So the brand damage from a breach, I believe, is higher for our airline than some of the other airlines out there.
Gardner: Given how important it is to your business, to your brand, how do you rationalize these approaches to security to the larger organization? I know that's probably not as prominent a problem as it used to be, because we can see directly the business implications of security issues. But how do you make security everybody's responsibility? Is that something that you have been trying to do?
Gullett: First, we're very lucky at Allegiant to have incredibly broad support from the C-suite level and the board of directors for our security program. That's not a benefit that every company has, but we do, and it certainly makes life easier in developing the procedures and processes, and the technologies, necessary to protect our customer data.
We came into the business at Allegiant with the idea that we have the typical triad of people, process, and technology to deal with in the information security program -- the three legs on a stool. If you miss one of those, you are going to be on your butt on the ground because the stool isn't going to work very well.
We focused on technology and process early on, because those were the easy things. Those were the low-hanging fruit. We've really moved into more of a stage of being people-focused now. In fact, much of our budgetary spend is on security awareness for our people.
We really had to look at how we best introduce security awareness to the entire company, and to make the company more culturally sensitive to information security. That extends from the customer service agent who's checking you in at the ticket counter all the way up to the board of directors.
The [security leadership] has certainly chimed in and made our board more aware of problems concerning information security. Recently U.S. Senator Edward Markey (D-Massachusetts) has also introduced legislation that specifically targets cyber security in the United States domestic airline industry.
That need to protect the data has to be recognized, and the most important part of protecting the data is the people that are handling the data. Awareness is really a big part of our program now.
Gardner: How did PCI-compliance form a trigger for your organization? What did that change mean for you, and maybe you could explain how you have gone about it at the process, people, and technology levels?
Gullett: Well, god bless compliance, because I think I got my first information-security job thanks to an auditor telling someone that they needed an information security guy because of Sarbanes-Oxley. And I joined Allegiant because of PCI. These various compliance regulations have certainly done wonders for the job market in information security. I can only imagine what it’s like with the data security and the EU General Data Protection Regulation (GDPR).
But, in regards to our travel into the world of PCI, Allegiant is also a unique airline in that the software that runs through the airline, the applications that run the airline, are proprietary. We actually write that ourselves. We have a large development staff and every aspect of the operation of the airline is run by custom software that we control and we write.
There are a lot of benefits to that because it allows us to be very agile and flexible if we want to make changes, but there is a downside. Some of the code dates back to the green screen days of the 1990s, and that code was going to be very difficult to bring into compliance from a PCI standpoint. It was just not written with security in mind, and while it wasn’t directly handling credit-card data, it was in the process scope.
A big concern was how we were going to ever bring a significantly non-compliant custom app that would take a great number of application-developer hours to bring it up to snuff and still meet a relatively tight schedule for becoming PCI-compliant. And so, at the time we looked at a number of different products out there and we thought, well, we can't solve every problem right now. So let’s bite off small chunks and we'll take care of that.
The first thing that looked like it would be fairly easy to do, or at least straightforward from a technology standpoint, was tokenization. And so, our search was, how can we tokenize the cards that we are storing. And that led us to stateless tokenization. We compared a number of different products, but we looked at HPE [Secure] Stateless Tokenization, and that was ultimately our choice for tokenization.
Interestingly enough, while we were on our search for what the best tokenization product was, I happened to read a press release on a website that talked about format-preserving encryption as a new technology that was going to become available -- and that actually became HPE SecureData Web. We found that by accident; it wasn’t even a product that was available at the time. It was going to be targeted at card acquirers, and we actually had a hard time convincing the sales folks to sell it to us as a different type of end-user.
That solved our application problem because it allowed us to encrypt the data that was passing through those legacy apps. Between the tokenization and the format-preserving encryption (FPE) SecureData Web product, we were able to dramatically reduce the overall scope of PCI data, and that finally led us to become compliant.
Gardner: Now, this sounds like, with custom apps, it could take months, even quarters. How much time did it take you, and how important was that to you?
Gullett: The time to implement any application that is outside of what we develop ourselves is always a concern, because that takes our developers, who now have to serve as integrators, off of projects that might lead to higher revenues for the airline or to solve a problem or offer a feature that the airline would like to do. And we're very focused on improving the overall business.
We found that the overall implementation of the HPE products was very efficient. In fact, I think we had one-and-a-half full-time equivalent (FTE) application developers on the project. It took them about three months, and that was integrating with multiple payment-card interfaces. I think we started at the end of October and we went live at the end January. So it was pretty lightweight from the standpoint of integrating significant products into our ecosystem.
Gardner: Secure stateless tokenization can often take organizations like yours out of the business of storing credit card information at all. You're basically passing it through and using various technologies to avoid being in a position where you could have a privacy problem. Was that the case with you, and did you extend that to other types of data?
Gullett: That was one of the marvelous parts of bringing the system online as it did take us from storing many, many millions of credit card numbers down to absolutely zero. We store no payment card numbers at this time. Everything is tokenized. The card data comes into our internal payment process and the system can send it off to the card acquirer to determine whether it should be approved or denied, and it’s immediately tokenized. So that has been a real win for the company -- just much less to worry about from the card standpoint.
Now from the standpoint of how we can encrypt or protect other data, we're looking at a number of possible scenarios now that we have gotten past the PCI hurdle. For example, while we don’t fly internationally with scheduled service, we do handle the charters for other companies. At some point, the company may well fly to international locations, and we will be collecting passport numbers. That would be the kind of thing we would also look at, in effect using some type of format preserving encryption, so that we're not storing the actual data.
We've gained a lot of experience with the product over the last three years and that’s going to be a fairly easy implementation that will offer a great deal of protection. But we can also extend that out to customer names, birth dates, and all kinds of different things and we are looking at that now.
Gardner: The HPE SecureData Web and the Page-Integrated Encryption are being used by a lot of folks for the webpage, of course, the browser-based apps, but that also can provide a secure way to go to mobile. Many people are interested in the mobile web, not necessarily just native apps. Is that something you have been able to use as well? The SecureData Web as a way to get to the mobile edge securely?
Gullett: We do use SecureData Web in our mobile applications. We've been using it since we initially integrated the product several years ago. In fact, that was one of the data points that we had to protect from Day One. So we have the app going out to the Internet, grabbing the one-time encryption key and encrypting that data in the application itself on the mobile device, on the Android device, the Apple device, and then sending that encrypted data back to our payment-processing system, passing through any systems in the middle as an encrypted form.
We also have a subsidiary that it is not directly airline-related that is also developing a payment-processing app for the business space it works within. Because they're developing a true native application for iOS, they're going to be developing with the SecureData Web SDK that’s been released for mobile devices, which will certainly be much easier.
Gardner: Chris, we hear a lot of times that security is a cost center, that people don’t necessarily see it as a way of bolstering business value or growing revenue streams. It sounds like when you can employ some of these technologies, create a better posture, it frees you up, it makes you able to innovate and transform. Has that been the case with you? Can you point to any ways in which you've actually been able to increase revenue? I know that for airlines it’s a fairly tight margin on the travel, but some of those ancillary services can be a make or break; is that the case here?
Gullett: Allegiant is a leader in what we call unbundled travel; we would rather sell you exactly what you want. When an airline says that they offer free bags, for example, they're not offering you free bags. It does cost to put those bags in the hold, to put those bags in the overhead and carry those bags on the plane with you. There is weight, and then that costs fuel. So, there is an expense associated with every aspect of your travel on an airline today; that’s just the way it is.
Allegiant’s unbundled services allow us to say to a traveler, “Well, sure, if you want to get on the plane and you want to bring something and put it under the seat, we'll sell you a seat on the plane. If you want to bring 40 pounds of baggage to put in the hold, we'll charge for that,” because not everybody wants to bring a 40-pound bag to put in the hold.
The thing about Allegiant with its proprietary application that runs the airline is that if we see an opportunity to offer a new service to the customer or a new ancillary service to the customer, we don't have to go to a third-party and say, would you please add this so we can offer this feature to the customer; we can just do it.
At the time, we were worrying about PCI compliance and how we were going to accomplish PCI compliance, we also had a project to begin charging for carry-on bags, the bags that go up in the overhead. We could either spend a lot of time retrofitting the legacy app for PCI or we could spend time generating revenue by offering this new feature to the customer that they would be charged for carry-on bags up in the overhead.
The seats on the plane, everything associated with the airline, have a very quick expiration date. When the plane takes off, an empty seat has no value and it will have no value ever again. When a seat takes off empty, we can’t sell that person a Coke, we can’t sell them a bag, we can’t sell them a [rental] car, we can’t sell them a hotel room; that's gone forever. So, speed to market is incredibly important for the airline industry and it may be more important for Allegiant.
In the case of our travails on PCI and how we were going to solve our PCI-compliance issue, we wanted to be able to add this feature to charge for carry-on bags. So now you have a choice. Do you spend a lot of time integrating and cleaning up legacy apps for PCI? Do you move ahead with something that could bring in millions of dollars in revenue? The answer, of course is that you have to be compliant with PCI. So, we have to do that first.
The fact that we were able to implement the necessary controls with the HPE products in about three months, with about one-and-a-half FTEs, meant that other application developers could spend time on that carry-on bag feature in our software, allowing us to go to market with that sooner than we would have otherwise.
Now, if you look at the fact that we went to market three months earlier than we would have normally, if we had spent three months of stopping everything to do nothing but PCI compliance. Instead, we were able to use that time to develop carry-on bag charging services, that is millions of dollars that would never have been captured in any other way, because it expires, it’s gone. Once the plane leaves the ground, you can’t charge anymore.
So there was a real delivery to the bottom line as far as a profitable feature was concerned by being able to roll out that carry-on bags feature sooner. We had a much easier, quicker, and lower resource-intensity standpoint ability to integrate, using the HPE Security products.
Gardner: So going back to our opening sentiment around the fact that you can’t just wall off data, meaning the more data, the better for your business and the more places that data can get to, the better. You've demonstrated that that’s also core to business innovation, such as growing revenue in new ways, and being agile and adaptive to very competitive markets. That’s a very interesting example.
Before we sign off, Chris, where do you go next? How do you think your security steps so far have enabled you to be more fleet, more agile, and perhaps find other business benefits?
Gullett: There is no substitute for delivering innovative solutions to problems that are well-known throughout the business, and helping that to build your credibility with the executives and the board of directors. Certainly, the solution to our PCI-compliance issues, which did get a lot of exposure to the company’s executives and the board, by being able to solve that quickly and without an impact to the operations of the airline, that brought information security awareness to a level that we had not previously enjoyed at the airline.
Although, if you talk to our executives and our board, they're going to tell you information security is very important, and I believe they believe that. The fact that you can demonstrate that you can deliver solutions that don't break the bank and do what they say they do, means a lot.
Going back to that three-legged stool, technology and the HPE Security products that we implemented for PCI are just one part. For example, if the folks aren't handling the credit cards properly or if they're not adequately protecting the data that they have on their mobile devices out in the field, our risk is just as great as a credit-card data breach would have been before we had implemented the tokenization. These are all things we kind of worry about.
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