As per my earlier post, I mentioned that the publication on PCI DSS reference architecture for cloud is interesting.
It is interesting because PCI DSS v2.0 (I still find it difficult to write ‘v2.0’!) just included additional guidance for virtualisation in the standard as below:
“System components” also include any virtualization components such as virtual machines, virtual switches/routers, virtual appliances, virtual applications/desktops, and hypervisors
Requirement 2.2.1 Note: Where virtualization technologies are in use, implement only one primary function per virtual system component.
Testing Procedure 2.2.1.b If virtualization technologies are used, verify that only one primary function is implemented per virtual system component or device.
So when the SSC made ‘major’ revisions to the standard and released a revised version to ensure the PCI DSS is understood clearly, I was amused and surprised at the same time that the Service Providers and some QSAs went ahead to certify or approve the relatively new technologies. The SSC has plans to work on various areas like Point-to-point encryption, Tokenisation, Mobile Payments and probably cloud technologies.
The Service Provider and The QSA
It is understandable that the vendors that got together to publish this reference architecture are keen to offer this service as a Service Provider. There is nothing wrong with this. Following this publication, on Dec 7 Amazon’s AWS cloud offering announced that they’ve achieved PCI DSS compliance as a validated Service Provider as well. A couple of good posts assessing this can be found here and here. Hence, if Merchants want it, they’ve got it.
One point I would like to highlight before moving on though is that for a vendor trying to offer such a service (Cloud-based PCI Compliant infrastructure), it is very important to get the QSA onboard early. More important is to identify that the QSA is well-versed with the infrastructure complexities of the cloud world and the underlying technologies and challenges (e.g. multi-tenancy). With AWS, they already have SAS and ISO certifications that should have made their compliance journey a bit easier. I’ve heard many experiences of QSAs not ‘understanding’ the solution they’re assessing resulting in waste.
The Merchant / The Customer
<<http://www.gillette.com/en/us/Products/Razors.aspx>>
I believe the above link is a good start to make the point. I’m sure not all of us have or use the ‘Fusion ProGlide Power Razor’ (//if reader=female then apologies). Although we’d all love to, not all men upgrade to the best Razor when released just because Gillette says it gives ‘Best Shave’ whereas the ‘M3 Power Razor’ only provides a ‘Good Shave’! It does depend on a number of variables for a Merchant or a customer to move to a cloud based offering just because it has various benefits. AWS has recently started offering a 'Free Usage Tier' to increase the cloud adoption.
And as mentioned in the linked post earlier, the Merchants require to ensure their own compliance in addition to making sure the Service Providers they contract with are PCI DSS Compliant.
The PCI SSC
The PCI DSS and other suite of standards (PA/PED DSS) have done a great job in bringing security to the forefront for a particular kind of data in the relevant organisations. There is a lot to adapt from for other sensitive data stored, processed or transmitted in organisations. Certainly, the stick behind the success of PCI DSS is the potential of fines by the card brands and the potential of direct monetary impact from data loss. However, there is a danger that the SSC will end up working on ‘additional guidance’ for new technologies unveiled by zealous and innovative vendors over the years. It is all good as long as the data i.e. the containers are secyored!
Thank you.