I’m attending the 2014 PCI Community Meetings in Orlando and the PCI SSC kicked off the conference with a presentation by Jake Marcinko, Standards Manager, on Business-as-Usual (BAU) compliance practices. The PCI DSS v3, released in November 2013, emphasizes that security controls implemented for compliance should be part of an organization’s business-as-usual security strategy, enabling organizations to maintain compliance on an ongoing basis.
Compliance is not meant to be a single point in time that is achieved annually to pass an audit. Instead, compliance is meant to be an ongoing state, ensuring sustained security within the Cardholder Data Environment (CDE). Security should be maintained as part of the normal day-to-day routines and not as a periodic compliance project.
To highlight the lack of business-as-usual security processes, Jake referenced the Verizon 2014 PCI Compliance Report, saying that almost no organization achieved compliance without requiring remediation following the assessment and there is dismally low continued compliance—only 1 out of 10 passed all 12 of the PCI DSS requirements in their 2013 assessments. But this was up from only 7.5% in 2012.
Four elements of ongoing, business-as-usual security processes were outlined:
Monitor security control operations
Detect and respond to security control failures
Understand how changes in the organization affect security controls
Conduct periodic security control assessments, and identify and respond to vulnerabilities
Jake mentioned that automated security controls help with maintaining security as a business-as-usual process, providing ongoing monitoring and alerting. If manual processes are used, they need to ensure that regular monitoring is conducted for continuous security.
The PCI DSS emphasis on business-as-usual security processes does not apply to any particular PCI DSS requirement, but instead applies across the standard. When considering how this applies to keys and certificates, manual security processes are unsustainable. A study by Ponemon Research found that, on average, there are 17,000 keys and certificates in an enterprise network, but 51% of organizations are unaware of how many certificates and keys are actively in use. Although some of these keys and certificates will not be in scope of the PCI DSS, a considerable number are used in the CDE to protect Cardholder Data (CHD).
In a recent webinar on PCI DSS v3 compliance for keys and certificates with 230 attendees, a poll revealed that over half (53%) either applied manual processes to securing their keys and certificates (41%) or did not secure them at all (12%). When specifically asked about their business-as-usual security processes for keys and certificates, more than half (53%) said they had no business-as-usual processes, but merely applied a manual process at the time of audit.
Organizations need automated security to deliver business-as-usual security processes for keys and certificates. This should include comprehensive discovery for a complete inventory of keys and certificates in scope of the PCI DSS, daily monitoring of all keys and certificates, establishment of a baseline, alerts of any anomalous activity, and automatic remediation so that errors, oversights, and attacks do not become breaches.
During his presentation, Jake noted that, for now, implementing business-as-usual security controls is a best practice according to the PCI DSS v3, and not a requirement. But he said that best practices often become requirements—so don’t wait! Start incorporating business-as-usual security practices now.