The Payment Card Industry Data Security Standard (PCI DSS) is one of the key components of security compliance, and it's set to improve in 2016. Among the areas of PCI DSS focus for the new year will be improved guidance on how organizations can comply with requirement for continuous monitoring and logging.
"The PCI DSS is a mature standard that has proven highly effective wherever it is adopted and used," Jeremy King, international director of the PCI Security Standards Council (PCI SSC), told eWEEK.
For PCI DSS to be effective, organizations must make security a priority and vigilantly maintain the standard's security controls at all times, King said. He added that it is only when organizations integrate people, processes and technologies, working together around the clock, that they really raise the bar on cardholder data security.
"PCI DSS is not just a once-a-year tick box exercise," King said. "Once that thinking is built into the DNA of a company, then they are where they need to be."
Among the many ways that security is integrated as a best practice in daily operations is through the use of continuous monitoring and logging. PCI DSS requirement 10 is titled "Track and monitor all access to network resources and cardholder data" and is among the most challenging components for compliance.
"Logging applications and systems is one of the fundamental best practices for information security," J. Andrew Brinkhorst, director of product management, Global Compliance and Risk Services, at Trustwave, told eWEEK. "It's essential to have logs that can provide information during or after an event in order to determine what's happening, or has happened."
In Brinkhorst's view, the challenge, not just for PCI DSS compliance but for good security overall, is knowing what systems, applications and events need to be logged. For a large organization, he said, logging at a level to be compliant with the PCI DSS specification can be overwhelming, as it likely requires capturing and retaining logs for many types of events, over many systems, and retaining them over a fairly long period of time.
"In a large organization, that likely means a complex system with a significant capacity, and the expertise to know what to log and how to effectively monitor it," Brinkhorst said. "That can be a real challenge for organizations that don't specialize in information security and is a reason companies might choose to outsource that aspect of their environment."
According to David Picotte, manager of security engineering at Rapid7, PCI DSS requirement 10 is and always has been a challenge for merchants. In Picotte's view, many organizations struggle with the sheer volume of log data being gathered, understanding what to alert on, and how to correlate multiple alerts into an indication of compromise (IoC).
"The challenge with the entire PCI DSS standard is that administrators often do the bare minimum to meet the requirement, interpreting to their advantage due to limited resources and time constraints," Picotte told eWEEK. "They should instead be looking to get value out of their logging process."
Merchants should work under the assumption that they will be breached, Picotte said. With that perspective in mind, logging can serve to detect a breach and help an organization react quickly to minimize impact.
Rob Sadowski, director of marketing at RSA, The Security Division of EMC, also emphasized the importance of logging and getting pervasive visibility into infrastructure that handles payment data.
"The challenges we see with requirement 10 are not necessarily meeting the letter of the requirement but complying with its intent," Sadowski told eWEEK. "It is not enough to simply collect logs and other data from the environment; it's about regularly reviewing the data collected to spot signs of compromise and then rapidly responding based on what's found to minimize damage or loss."
The PCI Security Standards Council is aware of the challenges that some organizations face in complying with the requirement 10 logging provisions of PCI DSS. King said it's an area PCI SSC is tackling with supporting guidance that will be enhanced this calendar year. To help organizations with this requirement, the council has created the special interest group called "Effective Daily Log Monitoring," he said.
"This special interest group will provide guidance and techniques to improve daily log monitoring to meet PCI DSS requirements, including available tools and examples/evidence from recent breaches," King said. "The 'Effective Daily Log Monitoring' group is working to finalize the Information Supplement and targeting publication in 2016."