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Compliance Headaches Continue

Staffing Cisco’s Compliance Solution demonstration a few weeks ago at Cisco Live 2012, I was beckoning passersby to test their knowledge of the Payment Card Industry (PCI) Data Security Standard (DSS) 2.0.  Some attendees shook their head and walked (ran) the other way.  Of the brave souls who ventured over to demonstrate their PCI knowledge, most spoke of the difficulties and challenges of dealing with not only PCI, but other mandates as well, such as HIPAA, FISMA and SOX. Attendees came from different industries such as Retail, Healthcare, Financial Services and Education, many of whom shared the same challenges with approach, best practices and the cost of compliance. Surprisingly, some were just beginning their journey, starting at ground zero, and were seeking guidance on how to meet the CIO’s “get compliant” edict with a balancing act between IT and Finance. Other customers were seeking guidance on specific product features that could address areas of management and reporting.

At a Table Topics session during the same event, other challenges around scoping, segmentation and wireless networks were discussed. Today, one of the challenges that merchants still face is with auditor inconsistency. This is an area that the PCI council is working hard to address by implementing training and best practices programs for QSA’s. To add fuel to the fire, in a recent QSA Insights Report, the cost of annual audits averages $225,000 per year for the largest merchants. Excluding technology, operating, and staff costs, the world’s largest acceptors of credit cards (also known as Tier 1 merchants) are spending an average of $225,000 on auditor expenses. 10 percent of these businesses are spending $500,000 or more annually on PCI auditors.  The full PCI DSS is available for download at:

https://www.pcisecuritystandards.org/security_standards/pci_dss_download.html

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Compromised Accounts, Stepping Stones

July 17, 2012 at 11:49 am PST

The list of account compromises over the past week is almost too long to list, and the numbers of verified or estimated compromised accounts has reached ridiculous numbers.  With the media spotlight on these current companies’ compromises, we’ll likely get more details on the security weaknesses, outright failures, and more from the narcissistic vulnerability pimps taking credit for exposing those security problems.

Aside from the obvious of changing passwords, what can you and your organization do?

I won’t prognosticate on the list of best practices that may have been violated in these compromises, but they will be reported following the long, detailed, and expensive investigations in coming weeks and months, because most of them will be well-known but for one reason or another not practiced.  The media reporting and the company’s public statements will cover those, and they will likely be worth a review for any significant points.  We can let them tell the story, again.

Instead let’s focus on some things that people may not know or understand that can actually improve your security around these incidents.  We highlighted a couple of these practices in the 2011 Annual Security Report, and more recently in the Emerging Threats Briefing at Cisco Live 2012.

First, let’s help our customers, users, and organizations.  Given the opportunity, many people will take the simplest and easiest way.  In the case of passwords, that means they will use their birthday, username, “password”, “123456”, and so on.  We’ll see these lists of bad passwords in coming weeks too.  It’s human nature, and too much work to try and remember all those passwords, right? Which leads to the second point of people that use the same password on multiple accounts (more on this shortly).  As security practitioners, professionals,…we too often are setting up our users and organizations to fail.  We have to do better, and here’s how.  Every security control must have technical controls that enforce and monitor that security control, or we have no idea if it is effective.  In the case of passwords, that means creating policies, security controls, and technical controls that require a user to create a strong password and change it regularly.  If we let a user create a password of “123456”, they have done as should be expected, and we have failed.  Even with the best account credentials, the accounts have to be monitored for suspicious activity with technical controls to alert security teams and users when, for example, a password is changed.  For a good reference list see: FY 2011 Chief Information Officer Federal Information Security Management Act Reporting Metrics.  Note the account activity items on the list: Locked out accounts, failed logins, dormant accounts, password aging…

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Product Security Incident Managers…A Closer Look

Product security covers quite a broad spectrum of knowledge areas within the realm of technologies applied to enable communications in this highly connected world. However, there is a natural tendency to first focus on the basic capabilities of the product itself. But later, questions arise such as “Is the product in operation vulnerable and if yes, what are the next steps to protecting against the vulnerability?” or “What can I do if I suspect a security issue with a product?” As much as one would like to sustain 100% immunity against any vulnerability or issue, events happen, inherent product weaknesses are discovered or new attack vectors and methods arise to expose ways to compromise a product’s operation or behavior. At Cisco, the people that rapidly converge on such occurrences or the potential for such occurrences are the Incident Managers (IM) who reside at the core of the Product Security Incident Response Team (PSIRT) within Security Intelligence Operations (SIO). I think it is fascinating how well this team seamlessly executes with the precision, efficacy, and timeliness on a day-in-day-out basis covering a large array of complex hardware, software, and technologies. The IM focuses on driving the underlying processes around the discovery of security disclosures and issues related to Cisco products and networks. I hope you will find that this article provides you with an informative and personal perspective on the IM role that is integral to the ongoing efforts essential to protecting the Cisco customer.

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Observations from HIPAA Conference – Time to Act?

On June 6-7, the National Institute of Standards and Technology (NIST) co-hosted a conference focused on HIPAA, the foundational U.S. health care information law. I attended the conference and came away with the sense that a) health care entities have begun to see clarity in the things they must do from an IT perspective to abide by the law’s requirement to protect patient information and b) they are motivated to do so through Federal moves to enforce the law.

The links between vague laws and concrete technical requirements to support them are usually ambiguous because the laws are written by non-technical lawyers and they often turn over implementation details to government departments.

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A Recipe for Cookies

This month marks the 63rd anniversary of the publishing of the novel Nineteen Eighty-Four, it might be interesting to take a look at what is currently the primary method used for tracking on the Internet, the Browser Cookie. Browser cookies are a subject with almost as much misinformation floating around as there is correct information.

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