Judging by the number of public breaches that we keep hearing about, it looks like the bad guys are far outrunning the good guys. We know it’s a big problem because as a company we get called in to sort out the problems most often once the horse has bolted.
In June of this year in the US with section 6.6 of the PCI Data Security Standards (DSS) becomes mandatory in the US will things change? From a UK perspective it’ll be interesting to whether it makes a change for the better. Online merchants that process credit card payments will either have to conduct a code review for their applications or install an application-layer firewall. The standard offers a choice, but there really isn’t any choice at all. If an organization is going to successfully protect its data, it needs to aim for preventing a breach, not passing an audit. This means, first, finding and fixing the vulnerabilities in your software, second, building security into the development process, and third, protecting your applications once they’re deployed.
Hannaford Bros, a supermarket chain based in New England, USA, passed a PCI audit and then got hacked. They lost 4.2 million credit and debit card numbers, which has led to 1,800 cases of fraud to date. Over the last two years, as the PCI standards have slowly been implemented, the number of data breaches has increased from 158 incidents in 2005 to 443 incidents in 2007, for a total of 212 million records. So judging by this, you’ll see the bad guys are still very much in the lead. And that’s why PCI keeps evolving. But, in order to win this battle, companies must invest in security, not just in compliance.
In the spring of 2005, someone broke into a Web application for the Assignment Management System of the United States Air Force. They stole 33,000 personal records. The USAF responded to their breach with a multi-million dollar effort to identify and eliminate their security holes. This initiative incorporated a heavy reliance on source code analysis, in order to fix the problems at the root cause, as well as targeted investments in application firewalls, web application scanning tools, and database firewalls. The key to their approach was having the right motivation. They didn’t launch this initiative to pass an audit. They did it to ensure their software was secure. The result has been a comprehensive and dedicated deployment. As software drives nearly every military activity today, we can all be a little more comfortable knowing they have the right approach to deal with the threat.
The PCI council knows that analyzing the code early is the right thing to do, as they stress the importance of building security into the development process. All of the following quotes come from the PCI council, and they all emphasize the importance of the code.
- “…it is recommended that reviews and scans also be performed as early as possible in the development process.” (1)
- “Tools should be made available to software developers and integrated into their development suite as much as practical.” (1)
- “The reviews or assessments should be incorporated into the SDLC and performed prior to the application’s being deployed into the production environment.” (1)
- “Develop all web applications based on secure coding guidelines such as the Open Web Application Security Project guidelines.” (2)
- “Review custom application code to identify coding vulnerabilities.” (2)
- “Cover prevention of common coding vulnerabilities in software development processes.” (2)
(2) Payment Card Industry (PCI) Data Security Standard, Version 1.1. September, 2006
Bottom line – build security in. If you want to have the best chance of passing a PCI audit, AND preventing a breach, fix the code first, and then monitor it in real-time.
PCI Section 6.6 is a productive step forward and encourages companies to do just this, but as with many standards, companies can interpret the mandates in many ways. A bad interpretation and a weak implementation will mean a false sense of security. Passing a PCI compliance audit is necessary, but compliance alone does not protect your company from a breach. So be ahead of the bad guys, put your efforts into ensuring your applications are secure – that way you’re be out there taking the lead.
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