Date: Fri, 23 Apr 2010 22:46:43 +0000
From: "Thor (Hammer of God)" <Thor@...merofgod.com>
To: Christian Sciberras <uuf6429@...il.com>
Cc: "security-basics@...urityfocus.com" <security-basics@...urityfocus.com>,
	full-disclosure <full-disclosure@...ts.grok.org.uk>
Subject: Re: Compliance Is Wasted Money, Study Finds

OK - so, when you say "to use PCI" what do you mean?  I get the feeling that you are equating being "PCI certified" as something people just "get" to show other people they are "secure."  Hence your use of "marketing propaganda."

People don't go through an audit and get PCI certified so that they can claim they are secure.  It doesn't work like that.  PCI (Payment Card Industry) compliances is what people HAVE to do, as in FORCED to do whether they want to or not, in order to be able to process credit cards.  If you process less than 1 million xactions per year, you can "self audit."  Can you lie?  Sure.  But you'll get your ability to process payments yanked if they catch you.  More than that requires an auditor.  If that auditor finds you have horrible security controls in place, you will fail.  If they pass you anyway, they can lose their certification to audit.  If you fail, you have x time to get with the program and be audited again.

It's just a way for the CC industry to make sure the people handling card info follow best practices for security.  That's all it means - it is a certification FOR the industry BY the industry.  No one ever said it mean people had "real security."  It means companies illustrate a base of practices required to handle consumer credit card data.  That's it.

And I totally agree with Mike Hale's comments about "if you are really secure, as in 'already secure' then it's cake."  I don't know that I would say "cake" as it depends on the scope of audit, but he's right.  If you already have a drive to secure your infrastructure, then PCI should be easy.  My requirements for security are far more strict than PCI.  Yours may or may not be, so you'll have to adjust as necessary.

Regarding code, I do believe that in PCI audits for dev that you have to illustrate an SDL, in which case things like XSS and BOs and such would be part of.

That's the skinny on PCI :)

t

From: Christian Sciberras [mailto:uuf6429@...il.com]
Sent: Friday, April 23, 2010 3:34 PM
To: Thor (Hammer of God)
Cc: Mike Hale; Stephen Mullins; full-disclosure; security-basics@...urityfocus.com
Subject: Re: [Full-disclosure] Compliance Is Wasted Money, Study Finds

No problem with that.

1) No.
2) Planning to, but no.
3) Heavens no.
4) I've looked into whether it was into our best interest to use PCI. (it was decided that it wasn't worth the trouble)
At that time, I knew about PCI but not its details, at which point we got someone to explain in detail for us.
The end decision wasn't mine, though.
We do take security as a main concern, however, it is preferred to have a more realistic approach to security rather then restrict employees' access (by signing some oath..).

Regards,
Christian Sciberras.



On Sat, Apr 24, 2010 at 12:22 AM, Thor (Hammer of God) <Thor@...merofgod.com<mailto:Thor@...merofgod.com>> wrote:
Marketing propaganda?  I have no idea what you are talking about.

Before commenting on PCI not helping at all and at the most being a false sense of security, let me ask:

1)      Does the company you work for perform PCI audits?

2)      Is the company you work for required to undergo PCI audits?

3)      Are you certified to be able to perform a PCI audit?

4)      Have you ever been directly involved with, as in contributing to, a PCI audit, and if so, in what capacity?

I would like to see some truthful expansion on the answers to those questions before continuing dialog about if PCI contributes to security or not.

t

From: Christian Sciberras [mailto:uuf6429@...il.com<mailto:uuf6429@...il.com>]
Sent: Friday, April 23, 2010 3:02 PM
To: Mike Hale
Cc: Stephen Mullins; full-disclosure; security-basics@...urityfocus.com<mailto:security-basics@...urityfocus.com>; Thor (Hammer of God)

Subject: Re: [Full-disclosure] Compliance Is Wasted Money, Study Finds

If you strive for security, and weave that into your network,
complying with PCI should be cake.

Uhm.. No. NO. PCI is an unnecessary hassle. What makes signing a document any more secure then having server facing the wild of the net?

Truth is, PCI doesn't help in security at all. It at most a sense of false security (and at least serves as a recreational exercise for auditors).

Thor, I'm not arguing with the article, since I didn't read it, and I won't bother to. I just want to point out some hard facts about PCI/DSS which you call "no big deal".
I surely agree with that, but what is not a big deal for you doesn't mean it ain't for the rest of the world.
What stops an uninformed programmer from complying with PCI/DSS (or at least, think to) and leave  RFI/XSS/whatever holes everywhere?
That said, security flaws are just about everywhere so no need to get critical about it. For now at least.

The point isn't "who" should be using credit cards or not, it's a matter of security.

I find it strange that you're excusing marketing propaganda.

Sincere regards,
Christian Sciberras.

On Fri, Apr 23, 2010 at 7:42 PM, Mike Hale <eyeronic.design@...il.com<mailto:eyeronic.design@...il.com>> wrote:
Look at the PCI requirements.

What's unreasonable about them?  Which portions are *NOT* part of
having a secure network?

If you strive for security, and weave that into your network,
complying with PCI should be cake.

On Fri, Apr 23, 2010 at 10:40 AM, Stephen Mullins
<steve.mullins.work@...il.com<mailto:steve.mullins.work@...il.com>> wrote:
>>I don't see what the hubbub is
>
> Some people in the information security industry actually care about
> securing systems and the information they contain rather than filling
> in check boxes.  Compliance may ensure a minimum standard is met, but
> it does not ensure or imply that real security is being maintained at
> an organization.
>
> As you say, PCI has become a cost of doing business whereas having a
> secure network is apparently not a cost of doing business.  This is a
> problem.
>
> Crazy notion, I know.
>
> On Fri, Apr 23, 2010 at 1:18 PM, Thor (Hammer of God)
> <Thor@...merofgod.com<mailto:Thor@...merofgod.com>> wrote:
>> How can you say it is "wasted"? It doesn't matter if you are a "fan" of it
>> or not, in the same way that it doesn't matter if you are a "fan" of the 4%
>> surcharge retail establishments pay to accept the credit card as payment.
>> Using your logic, you would way it is "wasted money," and might bring into
>> question the "value" of the surcharge, etc.  It is simply a cost of doing
>> business.
>>
>>
>>
>> If you choose to offload processing to a payment gateway, then that will
>> also incur a cost.  Depending on your volume, that cost may or may not be
>> higher than you processing them yourself while complying to standards.  The
>> implementation of actual security measures will be different.  But you can't
>> "handle" credit cards in the classic sense of the word without complying
>> with PCI.  If you pass along the transaction to a gateway, you are not
>> handling it.  If you DO handle it, then you have to comply with PCI.  If you
>> process less than 1 million transactions a year, you can "self audit."  If
>> you process more, you have to be audit by a PCI auditor.
>>
>>
>>
>> None of this MEANS you are secure, it means you comply.  If you don't like
>> PCI, then don't process credit cards, or come up with your own.  I still
>> don't really see what all the hubbub is about here.
>>
>>
>>
>> t
>>
>>
>>
>> From: Christian Sciberras [mailto:uuf6429@...il.com<mailto:uuf6429@...il.com>]
>> Sent: Friday, April 23, 2010 9:29 AM
>> To: Thor (Hammer of God)
>> Cc: Christopher Gilbert; Mike Hale; full-disclosure;
>> security-basics@...urityfocus.com<mailto:security-basics@...urityfocus.com>
>> Subject: Re: [Full-disclosure] Compliance Is Wasted Money, Study Finds
>>
>>
>>
>> it is simply part of the cost of doing business in that market.
>> A.k.a. wasted money. Truth be told, I'm no fan of PCI.
>> Other companies get the same functionality (accept the storage of credit
>> cards) without worrying about PCI/DSS (e.g. through Payment Gateways).
>> In the end, as a service, what do I want, an inventory of credit cards, or a
>> stable payment system? The later I guess.
>> As to security, it totally depends on implementation; one can handle credit
>> cards without the need of standards compliance.
>>
>> My two cents.
>>
>> Regards,
>> Christian Sciberras.
>>
>>
>> On Fri, Apr 23, 2010 at 6:07 PM, Thor (Hammer of God) <Thor@...merofgod.com<mailto:Thor@...merofgod.com>>
>> wrote:
>>
>> Another thing that I think people fail to keep in mind is that when it comes
>> to PCI, it is part of a contractual agreement between the entity and card
>> facility they are working with.   If a business wants to accept credit cards
>> as a means of payment (based on volume) then part of their agreement is that
>> they must undergo compliance to a standard implemented by the industry.  I
>> don't know why people get all emotional about it and throw up their hands
>> with all the "this is wasted money" positioning - it's not wasted at all; it
>> is simply part of the cost of doing business in that market.
>>
>>
>>
>> t
>>
>>
>>
>> From: full-disclosure-bounces@...ts.grok.org.uk<mailto:full-disclosure-bounces@...ts.grok.org.uk>
>> [mailto:full-disclosure-bounces@...ts.grok.org.uk<mailto:full-disclosure-bounces@...ts.grok.org.uk>] On Behalf Of Christopher
>> Gilbert
>> Sent: Thursday, April 22, 2010 4:48 PM
>> To: Mike Hale
>> Cc: full-disclosure; security-basics@...urityfocus.com<mailto:security-basics@...urityfocus.com>
>> Subject: Re: [Full-disclosure] Compliance Is Wasted Money, Study Finds
>>
>>
>>
>> The paper concludes that companies are underinvesting in--or improperly
>> prioritizing--the protection of their secrets. Nowhere does it state that
>> the money spent on compliance is money wasted.
>>
>> On Wed, Apr 21, 2010 at 5:44 PM, Mike Hale <eyeronic.design@...il.com<mailto:eyeronic.design@...il.com>>
>> wrote:
>>
>> I find the findings completely flawed.  Am I missing something?
>>
>>
>>
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>>
>> _______________________________________________
>> Full-Disclosure - We believe in it.
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>
> _______________________________________________
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