On 22/08/2010, at 8:43 AM, Miguel Arroz wrote:

> Hi!
> 
> On 2010/08/21, at 23:30, Q wrote:
> 
>>>   On the other hand, some of those questions have a very vague 
>>> interpretation, and others are just plain stupid (like asking if you have 
>>> an anti-virus installed on all your company computers, or asking if you 
>>> have a proper configured firewall, whatever that means). I'm not defending 
>>> PCI here, just saying you can get burned.
>> 
>> 
>> That's what the compensating controls section is for. The questions have an 
>> underlying risk that they try to protect against. In the case of antivirus 
>> software, it is to prevent the surreptitious installation of malicious or 
>> otherwise unauthorised software on your systems. If you can provide this 
>> security by other means then you detail it as a compensating control.
> 
>   That may be true for the anti-virus thing, but what about the Firewall? 
> What's a correctly configured firewall? In what way the firewall prevents an 
> attack using HTTP by exploiting a non-obvious bug in my app?

It doesn't. But it is about identifying potential risk, both present and 
future. In the case of a firewall you should be considering allowing only 
access to the required services and denying all else. If you do this you 
protect your future self from the risk of having software that doesn't need 
public access being used as an attack vector, even though you might not be even 
using that software yet. 

>   Some of those questions seem irrelevant or misleading to me. It looks like 
> some kind of "one size fits all" kind of certification which ends up being 
> pointless. I would rather have people who can THINK writing the code where my 
> credit card goes trough, than a firewall.

It's not just about the code you write. You need to think like a black hat, 
often there are far easier ways to compromise a system than head on. Your most 
vulnerable point is the thing you pay the least attention to, the PCI  self 
assessment is intended to get you to pay attention to as many facets of the 
card processing ecosystem as possible.

If you approach the PCI guidelines as "what's the minimum I need to do to be 
compliant" you have failed the exercise. If you instead see it as "what are the 
risks I need to consider based on these requirements and how do I protect 
against them" and adapt them to your environment you are off to a much better 
start.

Every one of the questions have merit, some of them may not be so obvious to 
your situation, but the ones that seem pointless are probably the ones you need 
to be the most sure of.

> 
>   But I have a bad temper, specially when filling endless irritating forms. ;)

I completely understand :)

-- 
Seeya...Q

Quinton Dolan - [email protected]
Gold Coast, QLD, Australia (GMT+10)




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