Memo to organizations that store cardholder data in virtualized environments, including the cloud: Don't skimp on security.
That's the main message contained in new guidance, released Tuesday by the Payment Card Industry (PCI) council, for organizations that handle cardholder data and thus must comply with the council's data security standard, PCI DSS.
"You're not relieved of any of the PCI DSS requirements here. If you've got to do them in the real world, you've got to do them in a virtualized world too," said Bob Russo, general manager of the PCI Security Standards Council, by telephone.
Already, PCI DSS version 2.0, which went into effect in January 2011, had specified that cardholder data stored in virtualized environments was covered by the standard. (Businesses still on PCI 1.2 must comply with the new version by the end of the year.) But when it came to investigating virtualization and its PCI implications in greater depth, "we were able to work within the existing compliance framework," said Kurt Roemer, chief security officer of Citrix, in a telephone interview.
Accordingly, "this is supplemental guidance, these are not new requirements within the standard," said Russo. That means PCI-compliant organizations storing cardholder data in virtualized environments won't have to start from scratch.
The PCI council's security caution over virtualization is justified, because virtualized environments are susceptible to types of attacks not seen in any other environment. Furthermore, many businesses embrace virtualization to cut costs, but skimp on securing the environment.
"Security tends to be an afterthought in any environment, not just virtualized environments, and our job is to help people understand this," said Russo. "We're always telling people this is about security, and not compliance. If you're secure, compliance comes along as a byproduct."
The new "PCI DSS Virtualization Guidelines" specifies four principles. First, PCI DSS security requirements apply to cardholder data, even if stored in virtualized environments. Second, organizations have to audit the risks--which may be unique--associated with using virtualized environments. Third, the council wants to see detailed knowledge of each relevant virtualized environment, "including all interactions with payment transaction processes and payment card data." Finally, the guidance warns that "there is no one-size-fits-all method or solution to configure virtualized environments to meet PCI DSS requirements" and said that specific controls and procedures will necessarily vary by environment.
To help organizations get a handle on PCI and virtualization, the new guidelines also detail techniques for assessing risk in virtualized environments, and specify which aspects of virtualized environments are--or aren't--within the scope of PCI compliance, and thus liable to be assessed during an audit by qualified security assessors (QSAs). "This is a document not only for the QSAs, but also for merchants and people wanting to use virtualized environments. So it better prepares them for what they're going to be asked by QSAs," said Russo.
Don't look for guidance on specific types of technology, but rather core virtualization security challenges. "If you look at the standard, we try to be as technology-agnostic as possible, and as we address virtualization going forward, we recognize that numerous areas will evolve--storage, virtual networking, cloud computing-- but the requirements to manage the technology will probably not change, rather the risks will evolve, and we'll address those," said Troy Leach, the council's chief standards architect, in a telephone interview.
The new guidance applies to storing PCI data in the cloud too. "What we did was adopt the NIST definition of cloud computing, and we abstracted that down to three types of computing as a service--software, platforms, and infrastructure," said Citrix's Roemer. In future PCI versions, "that's probably the one area of the document that would need to be updated more," he said, "but cloud computing is being used for PCI environments today, there are a lot of benefits in doing so."
The new guidance was produced in part by the PCI council's virtualization special interest group, which includes representatives from 33 different organizations--from Bank of America and Cisco to Southwest Airlines and Stanford University. Overall, it included "QSAs and auditors, merchants, and vendors, we had a broad brush of people across the PCI ecosystem," said Roemer, who leads the special interest group.
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