Let’s start off by saying this isn’t a way for us to make light of the current situation by using the word ‘Delta’ here. We all know how dangerous and virulent the current strain of COVID is and this isn’t a matter of writing an article simply to get a search hit on that word.
That being said, this is a topic that seemed a bit obscure, even to us who have been doing PCI-DSS for more than a decade now.
So the question that can sometimes pop up would be: Great, we got our PCI-DSS certification now, everyone is celebrating and patting each other on the back. In 2 weeks time after our AoC/RoC has been produced, our product management rolls out a new Application XYZ which deals with credit card information along with a new environment, database, systems etc. Is this Application XYZ included in our current PCI-DSS certification or not?
It’s a good question. Because the fact is that many view PCI-DSS as a point in time audit, whereby the audit is done at a certain time and not over a period of time. One might argue that during the audit itself, sampling will be done over a 12 month period, therefore it cannot be categorised as a strictly point in time assessment. Regardless how you categorise it, at the end of the audit, there is the big result: a compliant AoC/RoC pair. Don’t get us started on the dreaded Certificate of Compliance or CoC, or CoC-n-Bull in our terms. Enough of that certificate nonsense. As for the AoC/RoC pair, the scope is stated clearly in it, defining the audit scope, the boundaries, the applications scoped in, locations etc. So this is great. When we get a new application onboard, we just add in that application into the AoC, right?
Right?
Unfortunately, at this point, the QSA will say, not really. Once the AoC is out, it’s out. Unless you want to re-do the audit or to recertify, then yes, that new application can be added in.
Any change to the network architecture or infrastructures directly related to or supporting the CDE should be reviewed prior to implementation. Examples of such changes include, but are not limited to, the deployment of new systems or applications, changes in system or network configurations, and changes in overall system topologies.
PCI reminding us to stay focus!
So in this case, application XYZ falls under new application. The point of PCI-DSS is that, just because you deploy a new thing or new firewall or new application doesn’t mean you are no longer compliant to PCI-DSS. After all, PCI encompass the practice and process as well, so the council understands and advice that these changes be implemented into the PCI program and PCI processes ensures that this stays compliant. So in short, if you have application XYZ coming in, make sure the PCI controls apply to it and it will then be reviewed under the next audit and included into the PCI AoC of the coming year. Let’s just update the current Aoc and we all go home now, right?
Right?
But wait, you aren’t listening, says the auditor, you still can’t update the current AoC. The AoC is already fixed for that year, unless you want to do an audit. Again. Like a month after you have done and dusted your recertification audit for that year.
In most cases, these changes for our clients go through the maintenance cycle without and issue and the following AoC simply gets updated to include it. But what if the customer insist on having the CURRENT AoC updated? This could be due to requirements from their client, regulatory or what not. How do we put that application into the current AoC without spinning off the whole audit all over again?
In short, you can’t. You either wait it out for the next year audit OR you re-do your certification audit and nullify the previous one. However, this is where that little obscurity comes in. Delta assessment.
Now I’ve heard of Delta assessment for PCI, but it’s almost invariably related to PA-DSS (SSF now), PCI PTS, P2PE where basically, vendors who had completed, let’s say their SSF, can validate low risk changes to their application and do a delta assessment. In PTS, the delta is done by the PTS Lab, but for SSF, the SLC vendor can basically do a self attestation. However, we don’t see any such item or recourse for PCI-DSS.
Discussing with the auditors, we find that indeed, there are possibilities of a delta assessment to be done, although rare, and not exactly cost effective, since whatever the delta is doing, it’s would just have a short lifespan before the changes get swallowed up by the main PCI program once the yearly audit cycle rolls in. That’s why we rarely see this done. But I rarely see a tapir doing a jig in a tutu, but that doesn’t mean it doesn’t exist.
So what happens is that the auditor will formally audit this application and its environment and go through the certification process as would normally be done – except that this is limited to the application and systems. Once assessed, a formal delta AoC/Roc pair is released to supplement the existing AoC/RoC pair. And so that’s it, these supplement documents can then be shown together with the current AoC/Roc for verification purpose and in the next cycle, it’s consolidated back into the main RoC.
Now, this is fairly new to us. The logic of it is still beyond us somewhat because the whole point of PCI is for an environment to be able to handle changes and not have it audited everytime there is a significant change that occurs. Because every audit is costly and I’m sure every organisation has already got its hands full trying to sort out budgets during these times, without worrying about delta assessments.
The above is basically what we gather from discussions with auditor and not really from experience, because at the end, once the proposal was put out, our client thought better of it and decided not to pursue. So really, it’s still in the realms of theory and we may not be accurate in our assumptions. However, it’s still something interesting to keep in mind, though rare – like the tapir in tutu – it helps to know that this option does possibly exist.
Drop us a note at pcidss@pkfmalaysia.com and we will try to address all your concerns on PCI or other compliance matters like ISO27001, ISO20000 etc!
After being involved in PCI-DSS for almost a decade as well as other standards and guidelines like ISO27K, 27017, 9001, PDPA, GDPR, CMMI and a partridge in a pear tree, we can almost unanimously say: PCI-DSS is probably the most confusing standard out there. Not so much of the content itself – it’s fairly easy to understand in terms of the technical controls. The confusion begins at the start: Applicability and Scope.
Now scoping for PCI-DSS has been hammered by us in many articles over the years, so for this article, we will look at Applicability.
So what is applicability?
It simply means, who does this standard apply to? This is different from ‘scope’. A scope is basically what is being assessed? Applicability is basically: Do I need to do this thing?? For instance for simplicity:-
a) GDPR = Applies to entities processing EU personally identifiable information. Entities that may have a more global presence or require to deal with customers with a larger market distribution may end up being applicable to the GDPR.
b) PDPA = applies to entities in Malaysia processing personal information, which basically means almost everyone.
c) ISO27001 = guideline that can be used by any entity to cover their core processes. This may also be required by some governments on certain industries, e.g the government requiring CNII (Critical National Information Infrastructure), so simply, if you are CNII, then you should be doing the ISO27K.
d) CSA Star Alliance = standard for our data centers to apply, but it’s not mandatory (as far as we know).
e) TVRA = based on MAS (Monetary Authority of Singapore) requirement for financial institutions, so generally if you are regulated by them, then you need to get this done. It’s actually a subset of their Technology Risk Management Guidelines. It’s pretty much a mirror of Malaysia’s RMiT (Risk Management in Technology) subset of data center resilience section. As an aside it seems slightly comical that these two countries, tied so closely together in terms of history and economy would sit down and decide to name their federal bank’s IT standard so closely to each other. I mean, it’s like:
ii) Malaysia – Hmm, we can’t sound the same otherwise we might look like we aren’t original. Let’s flip it around and call it Risk Management in Technology!
Back to the subject, most standards out there has a reasonably clear idea of who it applies to. Even Bank Negara’s e-money guidelines or their baseline IT security requirements – apply to those regulated by them. HIPAA (not in Malaysia) applies to medical and healthcare entities.
Which leaves us with PCI-DSS.
From the onset, PCI-DSS applicability is actually very clear:
PCI DSS also applies to all other entities that store, process or transmit cardholder data (CHD) and/or sensitive authentication data (SAD).
PCI-DSS Standard
So in general, whenever you are storing, processing or even transmitting any part of the card holder data (PAN) or the sensitive authentication data, e.g track data, CVV etc, then PCI applies to you.
The confusion begins when these exact terms are used by those who are NOT doing any of these 3 (Store, Transmit, Process or STP) –lets call them NON STP– but still gets pulled into scope kicking and screaming like a child on his first day of kindergarten or adults on their first day of work after a holiday in the Bahamas. Examples are data centers, hosting providers, physical security storage companies (storing secure boxes for companies) – in their business model, they don’t deal with creditcards at all. But their customers may. Or may not. They don’t know. So for instance, if an insurance company decides to store their policy files with credit card information physically into a box and ship it to the physical storage company, how does the storage company gets yanked into ‘applicability’ of PCI?
The problem of section 12.8.2:
12.8.2 Maintain a written agreement that includes an acknowledgement that the service providers are responsible for the security of cardholder data the service providers possess or otherwise store, process or transmit on behalf of the customer, or to the extent that they could impact the security of the customer’s cardholder data environment
pci dss standard
The last part is where QSAs hook on – ‘impact the security of the customer’s CDE’. Now, just to be clear, 12.8.2 by itself has no indication that PCI is a requirement for these “NON STP” providers. It comes later in 12.8.4 and 12.8.5 where it states
12.8.4 Maintain a program to monitor service providers’ PCI DSS compliance status at least annually.
PCI dss standard
Argument on whether this relates to PCI-DSS compliance as a program or just service providers adhering to the PCI-DSS controls internally is an argument beyond time and space itself and requires a thesis to be written on it. Hence for now, simplicity wise, going by the standards and how many QSAs interpret it, multi factor authenticating providers gets pulled in. Hosting and cloud providers get pulled in. Storage vendors get pulled in. Cloud HSM and security providers gets pulled in. Fraud management gets pulled in. The whole thing about who could impact the security of customer’s environment gives QSAs a field day in including everyone in the party.
So applicability isn’t so straightforward after all. After determining anyone that stores, transmit and process credit/debit card with the PCI council members badges — now we have anyone that influences the security of the first group’s card data environment. This basically pulls almost everyone into applicability.
It doesn’t end there, however.
Because of the way PCI is structured, the PCI council actually washes their hands to determine who should be PCI compliant, and how they should be compliant. They pass that over to the individual card brands (I guess that’s themselves), who passes it to their banks connecting to their network, who in turn passes it on to their payment providers and who in turn passes either to their service providers or to their merchants. This is looked into in FAQ #1473, #1126, #1212 and a whole lot of other references. They always have this statement:
The PCI SSC recommends that entities contact their acquirer and/or the payment brands directly, as applicable, to understand their validation reporting requirements. Please contact the payment brands directly.
Everywhere to ensure everyone knows
When we were kids we used to play a party game whereby two teams have everyone sitting in two long straight lines. At the front of the line, the gamekeeper passes them a message, for instance “There is a blue wolf sitting in the Artic, looking at you with yellow, hungry eyes tonight” or something like that. Each kid will then need to whisper that message to the person behind him until it reaches the last person and that last person will have to go to the front and declare the message aloud, which invariably ends up something like “There comes wind that blew into the attic and sitting at me with fellow grey ice to the right.” And everyone laughs.
This is how it is in PCI. The message gets passed down and somehow along the way, the message gets so jumbled that we can only shrug and go, “OK…” Some messages we have heard (from customers who claim their banks said):
a) “You need to show us their SAQ and ROC together! The AoC is not enough” – Not really. If you are doing SAQ, there’s no ROC (Report of Compliance). Likewise, if there is a ROC, it’s not SAQ. Both have AoC though.
b) “Physical storage companies that store physical card data like forms needs to do SAQ C-VT” – We’ve seen this, where storage company gave a SAQ C-VT (virtual terminals) to their banks and was accepted. No, you can’t. A physical storage company, being a service provider should look at the SAQ D and then mark of the irrelevant controls (such as firewall etc) as Not Applicable.
c) “You can do SAQ A – as a payment gateway!” – A permutation of b) – whereby a payment provider gave us an SAQ A as proof of their PCI compliance. I think they just scanned through which is the shortest SAQ A and go, OK, let’s go for the easiest. No, SAQ A isn”t applicable to service providers. SAQ D needs to be done and controls that are relevant to be identified.
d) “You can store hashes with truncated data, its more secure!” – This is more of our previous post, where a company we spoke to started arguing on the merits of implementing truncation, encryption, hashing and storing everything together. No, it doesn’t work like that. If Truncated information and simple hashing is stored together, without a random salt, it may be easier to determine the card information through common sense brute force (please don’t talk about rainbow tables).
e) “They need me to be a level 4 certified gateway provider since I do less than 6 million transaction.” – In general service provider levels are only level 1 and level 2, according to visa and mastercard and amex. Secondly, the transaction levels for level 1 Visa and Mastercard are 300,000 volume, significantly lower than 6 million (which is for merchants). Amex has a higher threshold (2.5 million) but in general, we look at Visa/Mastercard since they are the most widely distributed.
f) “They insist on seeing a certificate of compliance – other documents are not allowed” – This has become so common that it’s painful. There is no such thing as certificate of compliance. These are all conjured up in the imagination of QSAs and PCI-DSS never issues certificates. It is technically as useless as showing your birth certificate to your bank. Yet, your bank insist upon it. FAQ #1220 of PCI addresses it below. So while it’s not wrong to issue certificates, but these are not considered “official documents”:
Because certificates and other non-authorized documentation are not officially recognized, entities that receive these documents to indicate their own compliance (for example, from a QSA or ASV) or another entity’s compliance (for example, from a service provider) should request that official PCI SSC documentation be provided. Any organization issuing, providing, or using certificates as an indication of compliance must also be able to provide the official documents.
FAQ #1220
g) “Since you only transmit and process card data and not store, no need for PCI-DSS” – We get this a lot from banks. Technically if you transmit or process card data , you should be PCI applicable. However, since banks have a big say in your compliance (for instance they may force you to be level 1 compliant even if you have zero transactions), on the flip side, if they say they don’t need it, then well, you don’t need it. You could probably argue with them and say you actually do need it from a technical point of view, but most customers just take the bank for their word and move on. The bank has made their risk assessment, and if they insist we don’t need to be PCI compliant and gives a black and white stating they don’t need – essentially they (the bank) is absorbing all the risk of non-compliance, aren’t they? Remember – PCI-DSS is generally a contractual obligation between parties. If the bank says contractually you are not required for PCI-DSS, then what’s the argument? In this case, we usually advice our clients to still undergo a self assessment to ensure they are aware of the security practices and we then get a nod of wise agreement before they shoo us out of the room, never to be heard from again. If they had a trapdoor button that drops us into the Rancor’s pit, I guess they would have used that.
h) And finally, most recently –“they say the since we only store PAN and without expiry and CVV, they said PCI-DSS isn’t applicable to us” – this is a bit mind boggling since this bank was an international bank and we think they should know better. But that doesn’t mean local banks know less, we’ll take it back. It’s just that international banks, being exposed in so many countries, would probably have the mindshare larger than local banks to know more about these things. But this one was – “You don’t store CVV and expiry date? OK – no problem, just go ahead and store PAN for all we care! Yeay!” Granted, the use of card information without information like CVV, expiry etc may not be as useful, but there are still other ways for PAN to be used – identity theft for one. Or, it can be used in combination with other information they already have. Or they just want to sell it on the dark web. PCI-DSS puts a big premium on PAN storage, so much so saying, if PAN is stored, all other information must be protected. And oh – CVV is considered Sensitive Authentication Data (SAD), and no, it cannot be stored post authorisation for whatever reason.
There are a whole lot more of strange things we have heard over the years from banks and service providers but those are the main examples. Again, I do not think it’s due to them purposely misinterpreting the standard, but like that party game, once the message gets passed down the line so many times, eventually it’s just going to end up like garbage. It’s like how I had to deal with my wife’s instructions to buy stuff from the grocery. It’s sanskrit to me…I mean how many different pasta brands are there and why must we buy such a specific one? Pasta’s pasta, no?
If you need us to help un-garble PCI-DSS for you, drop us a note at pcidss@pkfmalaysia.com and let us get to it!
To kickstart the New Year, we spent two full days with The United School Committees Associations of Malaysia for the Personal Data Protection Act training. Which is really a mouthful to say, so we will go by its more well known alias, Dong Zong.
Now, this is a rather unique engagement, for the simple fact that both our lead trainers in PDPA do not speak a lick of Mandarin. The first is proficient in Malay (as he is Malay), the second (which is me) is proficient in English – although he is technically a Chinese. While I am Chinese by birth, my proficiency in language is as follows: English, Malay, Cantonese, German, Minionese, Mandarin. That is to say, I can talk in German and Minionese far better than I can talk in Mandarin. For those who are wondering, Minionese is the official language used by the Minions, the yellow, annoying creatures that so love bananas and my sons so love watching.
Thankfully, we had another colleague who was proficient in Mandarin, but needed a bit of update on the subject, as he was from our technical deployment team for SIEM. So we had a bit of crash course for both. I had to do the introductions, demo and clarifications in broken mando-canto-eng-nese, and he had to crash course the updated PDPA training.
We can usually do the training quite comfortably, including the technical demonstrations (which consist of us actually searching for personal information on the internet during the training itself, demonstrating how easy it is if you know which tools and how/where to look). But this was made infinitely harder because of my lack of command in the language. To put it simply, it was like wrestling with a 300 pound catfish or a giant python. You know what to say in English, but the translation facility in your brain is broken and you just can’t get it out of your mouth and what ends up coming up is meaningless dribble, which my 2 year old son would probably appreciate, but not a roomful of teachers and educationists…who are championing the Mandarin language and the progressive advancement of the Chinese community as a whole. It would be great if I told them I was actually Middle Eastern or Eskimo, then they won’t expect so much from me – but I look like a total Chinese, so there’s no hiding the complete embarrassment of not being able to speak in Mandarin.
To Dong Zong’s credit, they did take it in stride, and our Mandarin-speaking colleague performed admirably (I think, since I did not understand him) and at the end of the two days, we were very well appreciated because somehow between the both of us, we got the job not just done, but done with great feedback and participation from the group. There were some really excellent Q and A time, which I had to answer in English/broken Cantonese and got translated properly. We even had a chance to go through Dong Zong’s implementation of PDPA and did a impromptu, live commentary on the areas to improve in privacy notice and other policies.
For a non-legal, practical way to implement and assess your company on PDPA, please drop us an email at avantedge@pkfmalaysia.com. We have done a lot of practical training on compliance to PDPA, and taken a lot of good info from the PDPA Commission itself. Our content is based on the one we developed with the deputy commissioner of PDPA during the time when we worked together to deliver our training to companies in Cyberjaya. Over the years we have enhanced it with demonstrations, as well as updated with the latest development of Malaysia’s Personal Data Protection Act.
We had our first PCI-DSS V3.0 training, with a total of 15 participants from various industries ranging from Oil and Gas, Payment (of course) and service organisations participating. It was held in our Training area in PKF HQ at the penthouse floor of 1 Mont Kiara.
We spent the day covering various topics, from the basics of PCI-DSS, its history, history of breaches, a deep dive into the 12 requiremens, V3.0 differences and changes and more importantly, implementation scenarios. SAQs (Self Assessment Questionnaires), a constant source of consternation amongst our clients were also covered in detail, and examples of which industry or business model would fit which SAQ was given.
The final part was probably the most fun. We went through scenario by scenario and broke down the attack and defence scenarios of the Target Retail Breach in 2013.
Thank you, all participants for making the training interesting and fun, especially not an easy task given the dryness of PCI requirements – specifically after a heavy lunch.
Additional training materials for V3.0 is found at this link.
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