Blogger: Randall Gamby

Two weeks ago the PCI Security Standards Council released the preliminary details of the PCI Data Security Standard (DSS) V1.2 that’s due out in October.  While many Analysts and Reporters have already written on the topic (I’ll be releasing an extensive update on Burton Group’s PCI coverage around the October release date), they really haven’t commented on what’s still not been addressed by the standard for enterprises still working on attaining compliance.

While I applaud the PCI Security Standards Council in further clarifying and adjusting the standard, a lot of work still needs to be done.  I receive about one or two PCI questions a week from our clients and they seem to revolve around a couple of topics I’ve yet to see addressed:

• Guidelines for selecting a Qualified Security Assessor (QSA) – while there are a large number of QSA organizations listed on the PCI Security Standards Council web site; they can’t really recommend a particular QSA for an individual organization.  This leads a lot of organizations to struggle with determining what criteria they should use in selecting a QSA for their certification.
• The role of the QSA – organizations are also still trying to understand the role of a QSA.  Should they get a QSA involved in the gap and remediation process in advance of certification?  If so, should it be the same QSA that will do their certification (knowing there’s a risk that the QSA will be pre-disposed to only care about certain vulnerabilities)?
• Industry-specific best practices – while each organization may have different infrastructures, in general, most industries try to be consistent with the major functions they perform.  So are credit card transactions handled differently between say, a major retailer with 10,000 POS systems and an insurance company that has hundreds of independent agents receiving remittances? Probably, so what are best practices around these industry-specific configurations?
• Virtualized environments – while the PCI Security Standards Council recognizes that some organizations have moved to virtual services for consolidation and management, the DSS really doesn’t provide guidelines for QSAs to evaluate and certify these environments.
• Monitoring and audit – while the PCI DSS recommends minimum timeframes for scanning, doing pen tests, etc. what are the real levels of monitoring and audit needed for ensuring security?  With the Hannaford and Okemo breaches that occurred (both where PCI compliant), neither discovered the problem until months after the breaches had happened.  So identifying what should be scanned and tested and if some of this should be on a continuous basis still requires refinement.
• PCI as part of an overall security model – what are the best practices around merging PCI security requirements into an enterprise’s overall security model?  Should it be maintained separately? Should some components be integrated with similar security mechanisms?  Should PCI be at the top of the security model and other configurations be based upon its requirements?  There are really no answers coming forth on this topic and the other question is where will they come from? Surely enterprises won’t expect the PCI Security Standards Council to tell them how to run their security services.

I will be providing Burton Group’s perspective on most of these questions in my upcoming report, but rather than relying on third parties to resolve these, I’d hope that the PCI Security Standards Council will be able to continue to provide answers to the questions they can in future updates, and releases, of the PCI DSS.

"The rigorous studies clearly show red-light cameras don't work," said lead author Barbara Langland-Orban, professor and chair of health policy and management at the USF College of Public Health. "Instead, they increase crashes and injuries as drivers attempt to abruptly stop at camera intersections."

Comprehensive studies from North Carolina, Virginia, and Ontario have all reported cameras are associated with increases in crashes. The study by the Virginia Transportation Research Council also found that cameras were linked to increased crash costs. The only studies that conclude cameras reduced crashes or injuries contained "major research design flaws," such as incomplete data or inadequate analyses, and were always conducted by researchers with links to the Insurance Institute for Highway Safety. The IIHS, funded by automobile insurance companies, is the leading advocate for red-light cameras since insurance companies can profit from red-light cameras by way of higher premiums due to increased crashes and citations.

And, of course, the agenda of the government is to increase revenue due to fines:

A 2001 paper by the Office of the Majority Leader of the U.S. House of Representatives reported that red-light cameras are "a hidden tax levied on motorists." The report came to the same conclusions that all of the other valid studies have, that red-light cameras are associated with increased crashes and that the timings at yellow lights are often set too short to increase tickets for red-light running. That's right, the state actually tampers with the yellow light settings to make them shorter, and more likely to turn red as you're driving through them.

In fact, six U.S. cities have been found guilty of shortening the yellow light cycles below what is allowed by law on intersections equipped with cameras meant to catch red-light runners. Those local governments have completely ignored the safety benefit of increasing the yellow light time and decided to install red-light cameras, shorten the yellow light duration, and collect the profits instead.

The cities in question include Union City, CA, Dallas and Lubbock, TX, Nashville and Chattanooga, TN, and Springfield, MO, according to Motorists.org, which collected information from reports from around the country.

Complicating factors is the impact (or lack thereof) of incidents on stock price.  Many researchers who identify themselves with the New School of Information Security (yours truly included) want to immediately look at stock price as a bell-weather metric for incident impact.  I think this stems from our days of slinging FUD, back when we could scream “Buy a firewall or we’ll have an incident and you’ll be on the front page of the paper and the stock price will go down!”  But these days notable incidents seem to suggest that the impact on stock price for an incident is short lived.  With qualifications, of course.

So what would/should we make of this from Money.co.uk?

£12million ($24m) Wiped off Helphire Stock after Malicious Email Sent to Clients

Car hire firm Helphire have taken Google to court after a malicious email sent from a Gmail account saw their shares plummet £12million in a single day.

The Bath-based business who specialise in providing replacement cars to ‘no-fault’ drivers involved in accidents on behalf of car insurance companies, initiated legal proceedings against the search engine giant as part of their attempt to find out who is responsible for sending the defamatory mailing.

Google are now known to have complied with the court order and have controversially supplied details of the email account and ISP used by the meddler.

Written under the psudoname Peter Franks, the 1200 word email is know to have been sent from a gmail account that was opened specifically for this purpose and closed a few minutes after the damage had been done…

…The misdemeanour couldn’t have come at a worse time for the struggling firm who have undergone a £45million rights issue and seen a 75% drop in the value of their stock already this year.

That last paragraph, for me, explains some of the difficulty in tying reputation damage to stock decreases.  It’s like when you read the headlines from Bloomberg about why the days stocks (or commodity) prices are up or down.  You know, the “Oil closes $3 higher on news that a notable South American dictator has a rather unpleasant boil in a very uncomfortable area” type of headlines.  You really do have to question the causality and correlation.  So in the Helphire case above - is this new drop in stock really because of the email sent?  If so, should we view that $24mil number as an independent data point to describe this sort of attack on reputation, or is the magnitude aggravated due to the long-term trend of stock price?

Even when we have “Objective Data” (an in-joke for Adam S.) like this decline in stock price, it is really difficult to provide any sort of precise estimate or measurement - about the future, present or past.  The best we can do is use ranges, distributions, that are reasonable based on evidence and observation.

So it’s worth filing away this sort of datum for future use - while dutifully acknowledging the qualifiers we might place around it.

So the questions I ask here - what should we make of this new information, and how should we view the $24million drop - they’re not rhetorical.  I am very interested in your views and welcome your comments!

One of my favorite banks in Thailand is K-Bank. With K-Bank I can simply walk up to an ATM machine and pay a mobile phone bill, purchase mutual funds, buy insurance, or transact an ever-growing list of services payable at the modern and sleek K-Bank ATM.

For example, tomorrow I fly to Chiang Mai in Northern Thailand and found K-Bank’s service amazingly better than in the US. For example, I booked my flight as usual (over the phone, but could have used the Internet) and told the reservation agent I was going to pay by ATM. He simply gave me a PayCode and told me I had three hours to go to the ATM and enter the PayCode to perfect my reservation.  I also got the PayCode via SMS.  This gave me the time I needed to make sure I had booked the perfect boutique hotel in Chiang Mai, the Fern Paradise.

Then, I went out into the beautiful Thai weather and completely my airplane reservation at the ATM machine; which also printed out a receipt with my flight details and reservation number.

It sometimes amazes me how much further advanced some services are in Thailand compared to the US. To me, it feels more secure not to use an on-line payment center or give out my credit card details over the phone. I can simply book a ticket, take a PayCode, and complete the transaction at a nice modern, shiny, K-Bank ATM machine.

Who knows, maybe soon I can select the perfect window seat at the ATM and the receipt will act as my boarding pass!

Don't worry, they won't be.

The key to understanding this is that this sort of contractual liability is part of a contract, and with free software -- or free anything -- there's no contract. Free software wouldn't fall under a liability regime because the writer and the user have no business relationship; they are not seller and buyer. I would hope the courts would realize this without any prompting, but we could always pass a Good Samaritan-like law that would protect people who distribute free software. (The opposite would be an Attractive Nuisance-like law -- that would be bad.)

There would be an industry of companies who provide liabilities for free software. If Red Hat, for example, sold free Linux, they would have to provide some liability protection. Yes, this would mean that they would charge more for Linux; that extra would go to the insurance premiums. That same sort of insurance protection would be available to companies who use other free software packages.

The insurance industry is key to making this work. Luckily, they're good at protecting people against liabilities. There's no reason to think they won't be able to do it here.

I've written more about liabilities and the insurance industry here.

What has certainly come as more of a surprise, though, is...]]> Mon, 21 Jul 2008 20:00:00 +0000 security controls information risk management security steady increase deep view incredibly broad adopt iso pci dss types The Long Road Towards an ISO 27001 "Tipping Point" (and a true Reader's Poll!) http://securityratty.com/article/033b2789311d93701b77cbecf63c9596 http://securityratty.com/article/033b2789311d93701b77cbecf63c9596 report, "Assessing the risks, costs and benefits of United States aviation security measures" by Mark Stewart and John Mueller, is excellent reading:

The United States Office of Management and Budget has recommended the use of cost-benefit assessment for all proposed federal regulations. Since 9/11 government agencies in Australia, United States, Canada, Europe and elsewhere have devoted much effort and expenditure to attempt to ensure that a 9/11 type attack involving hijacked aircraft is not repeated. This effort has come at considerable cost, running in excess of US$6 billion per year for the United States Transportation Security Administration (TSA) alone. In particular, significant expenditure has been dedicated to two aviation security measures aimed at preventing terrorists from hijacking and crashing an aircraft into buildings and other infrastructure: (i) Hardened cockpit doors and (ii) Federal Air Marshal Service. These two security measures cost the United States government and the airlines nearly $1 billion per year. This paper seeks to discover whether aviation security measures are cost-effective by considering their effectiveness, their cost and expected lives saved as a result of such expenditure. An assessment of the Federal Air Marshal Service suggests that the annual cost is $180 million per life saved. This is greatly in excess of the regulatory safety goal of $1-$10 million per life saved. As such, the air marshal program would seem to fail a cost-benefit analysis. In addition, the opportunity cost of these expenditures is considerable, and it is highly likely that far more lives would have been saved if the money had been invested instead in a wide range of more cost-effective risk mitigation programs. On the other hand, hardening of cockpit doors has an annual cost of only $800,000 per life saved, showing that this is a cost-effective security measure.

Hardening cockpit doors has the highest risk reduction (16.67%) at lowest additional cost of $40 million. On the other hand, the Federal Air Marshal Service costs $900 million pa but reduces risk by only 1.67%. The Federal Air Marshal Service may be more cost-effective if it is able to show extra benefit over the cheaper measure of hardening cockpit doors. However, the Federal Air Marshal Service seems to have significantly less benefit which means that hardening cockpit doors is the more cost-effective measure.