PCI DSS Vulnerability Scanning and Penetration Testing Hygiene

The Payment Card Industry Data Security Standard (PCI DSS) is an essential benchmark for businesses that store, process, or transmit cardholder data. The introduction of PCI DSS v4.0 brings several clarifications and new layers of complexity. Today, we’ll take a look at internal and external vulnerability scans and penetration testing. 

Vulnerability Scans (11.3.1.3 and 11.3.2.1)

One of the critical security controls that PCI DSS v4.0 emphasizes is the need for internal vulnerability scans. Companies must perform these scans after any 'significant change,' as defined by the standard. Significant changes include things like adding new hardware, software, or making considerable upgrades to existing infrastructure.

The scans aim to detect and resolve high-risk and critical vulnerabilities based on the entity’s vulnerability risk rankings. Following the scan, any detected vulnerabilities must be resolved, and rescans should be conducted as needed.

External vulnerability scans are equally important and follow the same triggering mechanism—significant changes in the environment. Here, the focus is on resolving vulnerabilities scored 4.0 or higher by the Common Vulnerability Scoring System (CVSS). As with internal scans, rescans are required as necessary to confirm that vulnerabilities have been adequately addressed.

Penetration Testing (11.4.2, 11.4.3)

Internal penetration testing is a more aggressive form of evaluation and should be conducted at least once every 12 months or after any significant change to the infrastructure or application. The testing can be carried out either by a qualified internal resource or a qualified external third-party, provided that there is organizational independence between the tester and the entity being tested. Notably, the tester doesn't need to be a Qualified Security Assessor (QSA) or an Approved Scanning Vendor (ASV).

Much like its internal counterpart, external penetration testing is required annually or after any significant alterations to the system. The testing must also be conducted by qualified resources and should follow the entity’s defined methodology for testing.

What Constitutes 'Significant Changes'?

PCI DSS v4.0 is pretty broad in what it considers to be 'significant changes,' effectively encompassing any new hardware, software, or networking equipment added to the Cardholder Data Environment (CDE), as well as any replacement or major upgrades to existing hardware and software in the CDE. The list is exhaustive and is aimed at ensuring that any changes, no matter how seemingly minor, are given adequate attention from a security perspective.

Summary of Requirements

The PCI DSS v4.0 requirements for vulnerability scans and penetration testing provide a structured approach for entities to keep their data environments secure. While these requirements might seem stringent, they offer a well-defined framework for securing cardholder data against the backdrop of ever-advancing cyber threats. Adhering to these requirements is not just about ticking compliance boxes; it’s about taking the necessary steps to protect your organization and its stakeholders.

• Internal vulnerability scans:
• 11.3.1.3 Internal vulnerability scans are performed after any significant change as follows:
• High-risk and critical vulnerabilities (per the entity’s vulnerability risk rankings defined at Requirement 6.3.1) are resolved.
• Rescans are conducted as needed (significant changes..).
• External vulnerability scans:
• 11.3.2.1 External vulnerability scans are performed after any significant change as follows:
• Vulnerabilities that are scored 4.0 or higher by the CVSS are resolved.
• Rescans are conducted as needed (significant changes..).
• Internal penetration testing:
• 11.4.2 Internal penetration testing is performed:
• Per the entity’s defined methodology, at least once every 12 months
• After any significant infrastructure or application upgrade or change
• By a qualified internal resource or qualified external third-party
• Organizational independence of the tester exists (not required to be a QSA or ASV).
• External penetration testing:
• 11.4.3 External penetration testing is performed:
• Per the entity’s defined methodology, at least once every 12 months
• After any significant infrastructure or application upgrade or change
• By a qualified internal resource or qualified external third party
• Organizational independence of the tester exists (not required to be a QSA or ASV).
• Significant changes are defined in PCI DSS to include (PCI-DSS-v4_0.pdf page 26):
• New hardware, software, or networking equipment added to the CDE.
• Any replacement or major upgrades of hardware and software in the CDE.
• Any changes in the flow or storage of account data.
• Any changes to the boundary of the CDE and/or to the scope of the PCI DSS assessment.
• Any changes to the underlying supporting infrastructure of the CDE (including, but not limited to, changes to directory services, time servers, logging, and monitoring).
• Any changes to third party vendors/service providers (or services provided) that support the CDE or meet PCI DSS requirements on behalf of the entity.

Using Maturity Levels and Qualitative Measurement for Visualizing Technology Implementations

Check out this maturity model. What does it mean to measure the maturity of a technology implementation qualitatively? And how can maturity levels help visualize the current and future states to meet control requirements? 

Let's unpack these concepts and show how qualitative measures can enrich the maturity model process, particularly with the use of visualization techniques like bar or radar graphs.

Maturity models serve as diagnostic tools, usually consisting of a sequence of maturity levels that provide a path for improvements. These models are vital for benchmarking and identifying the best practices that need to be implemented for organizational success. In technology implementation, they can gauge how effectively an organization is meeting its control requirements—be it in data security, governance, or software development lifecycle.

The Qualitative Dimension

While numbers and metrics provide a certain level of clarity, they often lack context. Qualitative measurements step in here to provide nuanced insights into otherwise cold data. Through expert interviews, case studies, and scenario analyses, qualitative assessments can address 'how' and 'why' questions that numbers cannot.

One of the powerful ways to present the qualitative aspect of maturity models is through visualization. A bar or radar graph can be used to overlay the current and future states of an organization's maturity levels.

Current State

Imagine a bar graph where the X-axis represents different control requirements like "Data Encryption," "User Access Management," and "Compliance Monitoring," and the Y-axis represents maturity levels from 0 (Non-existent) to 5 (Optimized). The current state can be represented by blue bars reaching up to the current maturity level for each control requirement.

This visualization allows stakeholders to immediately grasp which areas are well-managed and which need improvement. It's not just about the height of the bar but the story behind each bar—which can be enriched by qualitative inputs like expert opinions, employee feedback, and process reviews.

Future State

In the same graph, future state scenarios can be represented by a different color—say, green bars—overlaying or adjacent to the current state bars. These future state bars are not arbitrary but are informed by qualitative measures like scenario planning, risk assessments, and strategic discussions.

The juxtaposition of current and future states in one graph offers a compelling narrative. It shows where the organization aims to be, providing a clear vision for everyone involved.

Utility of Qualitative Maturity Models

Maturity levels, when fleshed out with qualitative measurements, offer more than a snapshot of the present; they provide a roadmap for the future. Visual representations like bar or radar graphs give life to these qualitative insights, making them easy to understand and act upon.

So, the next time you consider assessing your organization’s technology maturity, think beyond numbers. Look at the stories those numbers can tell, and use qualitative measures to fill in the gaps. And don't just keep these insights in spreadsheets and reports—visualize them. 

Combine qualitative measures with visualization techniques and build a more meaningful, actionable, and comprehensive roadmap. Aim for a balanced, nuanced, and visually engaging approach to understand the current state and opportunity for improvement.

Example Output 

Here's a quick assessment of an organization's adherence to the NIST Privacy Framework. The beauty of this method - by the way - is that it's fast and easy to create this chart using qualitative measures. Search for the Privacy Framework spreadsheet under the downloads section if you want a copy of this.

NIST.SP.800-66r2.ipd Worksheet - HIPAA Indexed on NIST

HIPAA to NIST and NIST to HIPPA indexed worksheets in a single spreadsheet based on the Initial Public Draft (ipd) are posted on the downloads website. Look for the workbook 2022 HIPAA Crosswalk SP 800-66 ipd Table 12 on:

www.compliancequickstart.com.

Numbers and Narratives: The Power of Qualitative and Quantitative Feedback

While technological prowess is crucial for cybersecurity, human factors are often the linchpin that determines an organization's susceptibility to cyber threats. As we navigate this ever-evolving landscape, the role of learning programs in enhancing cybersecurity awareness cannot be overstated. But how do we measure the effectiveness of these initiatives? The answer lies in a meticulous blend of quantitative and qualitative feedback.

The Quantitative Dimension

In the realm of cybersecurity learning programs, quantitative data acts as the backbone that offers empirical evidence of program effectiveness. This data, collected through various channels—from real-world cybersecurity incidents and metrics on employee reporting to targeted simulations and longitudinal studies—provides a measurable barometer of your organization's cybersecurity posture. It can also help tailor training materials to specific departments, evaluate ROI, and keep content up to date. This section will detail the key types of quantitative data that you should focus on, offering a robust framework for continuously enhancing your cybersecurity initiatives through actionable metrics.

1. Cybersecurity Incident Data - Utilize real-world data on past incidents to simulate realistic scenarios in your training programs. For example, if there has been a rise in phishing attacks, including similar scenarios in your learning modules can help prepare the workforce better.
2. Metrics on Incident Reporting - Review how many employees report potential cybersecurity events pre- and post-training. An increase in reports post-training could indicate higher awareness.
3. Simulated Attack Responses - Phishing simulations can provide invaluable data. If 90% of your employees ignore a phishing email post-training compared to 50% pre-training, you know you’re on the right track.
4. Longitudinal Data - Track the program's impact over time to identify trends. Maybe the initial spike in awareness drops after six months, indicating a need for refresher courses.
5. Employee Testing Data - Compare employee cybersecurity test scores before, immediately after, and three months post-training to assess knowledge retention.
6. Performance by Department - Do tech departments outperform sales in cybersecurity awareness? This could guide department-specific training.
7. Training Attendance and Completion Rates - Low attendance or completion could indicate that the training is too cumbersome or not engaging enough.
8. Quantitative Surveys and Costs - Use closed-ended surveys for quick, quantifiable feedback. Also, calculate the per-participant cost of developing and delivering the program for ROI assessment.
9. Privacy and Technical Metrics - Track the frequency and type of privacy or cybersecurity events to identify the need for role-based training. Changes following technical training—like a reduction in accounts with privileged access—can also be invaluable metrics.

The Qualitative Dimension

While quantitative metrics provide the hard facts, it's the qualitative data that enriches our understanding by adding context, nuance, and depth to these numbers. Qualitative feedback captures the human elements that are often overlooked in cybersecurity initiatives. From capturing employees' responses about the program's delivery and content to conducting focus groups for in-depth insights, qualitative data allows us to gauge the intangibles that make or break a learning program. In this section, we will delve into various types of qualitative feedback, including presenter evaluations, open-ended surveys, and even observations from the training sessions, to provide a more holistic assessment of your cybersecurity education efforts.

1. Presenter and Program Feedback - Encourage employees to share feedback on trainers and program content to make real-time improvements.
2. Open-Ended Surveys and Reports - Use these to gather nuanced opinions. Maybe the training material is excellent, but the pace is too fast?
3. Focus Groups and Observations - Conduct these with a cross-section of employees to get richer insights into the learning experience, identifying areas for improvement.
4. Suggestion Box - A suggestion box allows employees to provide candid feedback and innovative ideas for program improvement.

A Marriage of Metrics and Mindsets 

Combining quantitative data with qualitative insights will not only paint a comprehensive picture of your program's effectiveness but will also guide data-informed decisions for future improvements. For instance, if your quantitative data indicates high knowledge retention but qualitative feedback points to low engagement, you may need to inject more interactive elements into your program. Because when it comes to cybersecurity, an empowered workforce is your best line of defense. 

And if you haven't already, check out NIST Special Publication 800-50 and look for the upcoming Rev. 1. This is a comprehensive guideline that serves as an invaluable resource for information security education, training, and awareness. Thank you to NIST and the industry authors and contributors for your tireless work in advancing the field and providing a foundational resource for cybersecurity professionals everywhere.

2023 PCI DSSv4 to NIST 800-53r5

I ran across this again today working on an internal project for VMware. We are a team of likeminded professionals who enjoy quality work and sharing with the community to raise the bar for everyone.

What struck me when I reopened this workbook is remembering the many very, *very* long days. Mapping is an incomplete science, filled with subjective relationships. However, starting from scratch, using homegrown tools and my own reading through the controls, I remapped as accurately as I could the relationship between the PCI DSS and the body of controls established by NIST SP 800-53r5.

We have our own internal agendas and projects related to this work. However, the data here can help someone else struggling with the volume of frameworks and managing the complex relationships between all of them.

I stand by the mapping as 90% correct. I've learned through the years there are usually ways to improve the accuracy of subjective data. Please let me know if you find an error! Use as you see fit. Look for 2023 PCI DSSv4 to NIST 800-53r5 on davischr2/Cloud-Documents (github.com) or Blog Downloads (compliancequickstart.com).

#pci #pcicompliance #nist #sp80053r5

Cross Posted on LinkedIn: PCI DSS to SP 800-53r5 | LinkedIn

NIST Privacy Framework Maturity Model

The NIST Privacy Framework (PF) is an interesting model for building and assessing a formalized privacy program. Sure - I agree - it's not as detailed as what can be found on ARMA, but it's familiarity with the NIST Cybersecurity Framework (CSF) makes it approachable and easier to share with stakeholders. 

This important distinction can help drive interest and stakeholder involvement.

The implementation of any model or checklist is only useful as a point in time assessment, and finding a way to extrapolate quantifiable growth is the key to successful implementation and gaining value from the effort. 

And so - along those lines - please enjoy access to a free tool for measuring your privacy framework as it stands currently versus your desired state during the next periodic timetable you choose to set. 

It's unlocked. Use as you see fit: Blog Downloads (compliancequickstart.com) or davischr2/Cloud-Documents (github.com)

Cross posted on LinkedIn: NIST Privacy Framework Maturity Model | LinkedIn

Interconnected Disciplines: Security | Compliance | Privacy | Audit | Information Governance

As the lifeblood of the modern enterprise, information is ceaselessly processed, transmitted, and stored by people, processes, and tools. Have you ever thought about the closely interrelated relationships between each organization that has a vested interest in that data?

A considerable part of the enterprise is dedicated to using - consuming - information. Meanwhile, there are others, behind the scenes, laboring to ensure the organization can utilize the information without any repercussions. The data must not only be protected but also be compliant, managed properly, and audited periodically.

Introducing: Security, Compliance, Privacy, Audit, and Information Governance organizations.

Each of these play a distinctive role, yet they often operate in close concert. 

• Security is about fortifying the enterprise against threats and ensuring the confidentiality, integrity, and availability of its data. 
• Compliance takes charge of ensuring the organization's adherence to relevant laws and regulations. 
• Privacy manages personal data responsibly, safeguarding the rights and expectations of the individual. 
• Audit plays a vital role in conducting systematic reviews of the company's records and operations to ensure transparency and adherence to established protocols.
• Information Governance manages information at a strategic level, providing a framework that aligns data handling processes with the overarching goals of the enterprise.

Let's dive a little bit deeper into each one of these.

1. Security Organization:

The Security Organization is the pillar that safeguards the entire process of customer's credit card transactions. The organization employs advanced security protocols and measures, providing a secure environment for data transmission and storage. Without the Security Organization, all the other organizations would be susceptible to significant risks, as their functions entirely rely on the secure foundation built and maintained by the Security Organization.

2. Compliance Organization:

The Compliance Organization is the critical player in aligning operations with external regulations and internal policies. Without the Compliance Organization's thorough knowledge of laws and regulations such as PCI-DSS, and its tireless efforts to maintain compliance, the company could face substantial legal and financial penalties, reputational damage, and loss of customer trust. This fundamental role places the Compliance Organization at the core of the business's sustainability and success.

3. Privacy Organization:

In today's digital age, customer trust hinges heavily on how businesses handle their personal data. The Privacy Organization's role in ensuring the use of customer's credit card information adheres to privacy laws is paramount. Without the Privacy Organization's diligent monitoring and management of personal data, the company risks severe legal ramifications and damage to its reputation. Their critical role in maintaining customer trust puts them at the heart of the organization's operations.

4. Audit Organization:

The Audit Organization, with its responsibility of conducting independent and rigorous reviews, ensures that transactions are being processed accurately and securely. They play an irreplaceable role in detecting irregularities, enhancing process efficiency, and ensuring that the company's financial statements are accurate. The insights they provide enable the company to maintain financial integrity and operational efficiency, making them indispensable to the organization.

5. Information Governance Organization:

The Information Governance Organization, as the policy maker for information management, is the driving force behind how credit card information should be handled, stored, and deleted. They shape the company's strategy on data usage, storage, and security. Without their directives, other organizations wouldn't have the guidelines they need to perform their roles effectively. They serve as the architect of the company's information management strategy. This team establishes the framework for how information is created, stored, used, archived, and deleted across the organization. They align all information-related processes and policies with the organization's overall strategy and goals, ensuring that data supports and advances business objectives.

Criticality of Working Together

Diverse information types necessitate the involvement of multiple organizational bodies. A large spectrum of information forms the backbone of our operations.

This reality underscores the need for an integrated, collaborative approach in dealing with the varied, yet interconnected, dimensions of information. It's crucial that we create a culture that emphasizes collaborative goals, where each team sees their unique responsibilities as components of the collective success. To that end, fostering cross-functional collaboration and implementing diverse team reviews can engender a richer understanding of each team's contributions and insights.

Open communication, underlined by active listening and mutual respect, forms the bedrock of this collaborative culture. The exchange of ideas, challenges, and insights can catalyze solutions that incorporate diverse perspectives and approaches. Establish feedback mechanisms that value different perspectives further enhances your decision-making process and strengthens inter-team relations.

The information and the organizations that manage it are intricately intertwined, calling for a deliberate and proactive approach to collaboration and open dialogue. This approach is the key to leveraging our collective strength, ensuring the integrity of our operations, and driving our collective success.

SOC Trust Services Criteria (TSC) AICPA Excel Spreadsheet Workbook

I've combined information from multiple sources, created a numbering scheme, and broken down information into a format that is easier to review and digest than what I have seen. Enjoy.

You can find the result under Blog Downloads (compliancequickstart.com). 

Updated Format to New FedRAMP® NIST SP 800-53r5 Controls Workbook

I've updated and cleaned up the posted NIST SP 800-53r5 FedRAMP® controls workbook located under the FedRAMP Resources. For example, I've included a worksheet that allows simple filtering and sorting for comparative analysis across control sets.

You can download it from www.compliancequickstart.com. Look for 2023 FedRAMP Control Baselines. If I was going to use the information, this is the format in which I would start. Have fun.

Direct Link here.

IT Audit Process - Review

I'm reposting for others to review because this keeps coming up. This is helpful if you don't have an audit background so that you can appreciate what goes into the audit process.