05-03-13 | Blog Post

PCI-Ready? Not Enough for Fully Compliant PCI Hosting

Blog Posts

Obscure marketing lingo happens to the best of us, and one of those potentially deceptive terms, when it comes to compliant hosting, is <insert your compliance>-ready. Whether it’s PCI-ready, or HIPAA-ready, it’s a key indicator that the hosting provider using the term is not actually compliant, or that they may not provide all of the technical and managed services needed to help your company meet compliance.

For example: if your PCI hosting provider lists ‘log monitoring’ as a managed service within your PCI compliant hosting package, it might not actually fulfill the complete requirement. PCI standard 10.3 requires that you:

Record at least the following audit trail entries for all system components for each event – a whole list of events follow, including user ID, type of event, data and time, success or failure indication, etc.

But the requirement 10.6 also requires log review:

Review logs for all system components at least daily. Log reviews must include those servers that perform security functions like intrusion-detection system (IDS) and authentication, authorization, and accounting protocol (AAA) servers (for example, RADIUS).

Going beyond automated logging, which a PCI-ready hosting provider might offer, is the need for either you or your provider to review and analyze logs daily. This is a time-consuming burden that might be better outsourced if possible – which is possible, as long as you avoid the PCI-ready solutions out there that don’t actually give you everything you need, such as daily log review.

Daily Log Review

Offsite backup and disaster recovery are two services often overlooked by those that need to meet PCI compliance, despite the clear requirements for a data backup plan, disaster recovery plan, emergency mode operation plan, testing and revision procedures, and application and data criticality analysis (9.5 and 12.9.1).

PCI Offsite Backup

PCI requirement 9.5 calls for backups to be stored in a secure location and preferably in an offsite location/facility, or data center. Auditors need to review the physical security of a PCI compliant data center to ensure proper authorization, control access and environmental controls are all in place for the highest standards of security.

Why pay for an incomplete solution and have to fill in the gaps? Don’t settle for PCI-ready, strive for fully PCI compliant with all of the essential managed services, and know which PCI standards your provider can fulfill vs. where you need to pick up the slack.

This handy chart of PCI compliant services matched with each of the PCI requirements can help you determine what can be solved with a PCI compliant hosting solution:

PCI Requirements PCI Compliant Services
10.6: Review logs for all system components at least daily.
10.3: Record at least the following audit trail entries for all system components for each event – including user ID, type of event, data and time, success or failure indication, etc.
10.7: Retain audit trail history for at least one year, with a min. of three months immediately available for analysis (online, archived, or restorable from back-up).
daily-log-reviewDaily Log Review
Monitoring and analyzing user and system activity can help detect patterns of normal use and potentially malicious users. Daily log review is the process of regularly reviewing and reporting on log activity. While some providers may offer logging (tracking user activity, transporting and storing log events), Online Tech provides the complete logging experience with daily log review, analysis, and monthly reporting.
10.5.5: Use file-integrity monitoring or change-detection software on logs to ensure that existing log data cannot be changed without generating alerts.
Deploy file integrity monitoring tools to alert personnel to unauthorized modification of critical system files, configuration files or content files. Configure the software to perform critical file comparisons at least weekly.
file-integrity-monitoringFile Integrity Monitoring (FIM)
Monitoring your files and systems provides valuable insight into your technical environment and provides an additional layer of data security. File integrity monitoring (FIM) is a service that can monitor any changes made to your files.
6.6: For public-facing web applications, ensure: Verify that public-facing web applications are reviewed (using either manual or automated vulnerability security assessment tools or methods), as follows:

  • At least annually and after any changes
  • By an organization that specializes in application security
  • That all vulnerabilities are corrected, and the application is re-evaluated after corrections

Verify that a web-application firewall is in front of public-facing web applications to detect and prevent web-based attacks.

web-application-firewallWeb Application Firewall (WAF)
Protect your web servers and databases from malicious online attacks by investing in a web application firewall (WAF). A network firewall’s open port allows Internet traffic to access your websites, but it can also open up servers to potential application attacks (database commands to delete or extract data are sent through a web application to the backend database) and other malicious attacks.
8.3: Incorporate two-factor authentication for remote access (network-level access originating from outside the network) to the network by employees, administrators, and third parties.(For example, remote authentication and dial-in service (RADIUS) with tokens; or other technologies that facilitate two-factor authentication. two-factor-authenticationTwo-Factor Authentication
Online Tech offers two-factor authentication for VPN (Virtual Private Network) access as an optimal security measure to protect against online fraud and unauthorized access for clients that connect to their networks from a remote location. 
11.2: Run internal and external network vulnerability scans at least quarterly and after any significant change in the network (such as new system component installations, changes in network topology, firewall rule modifications, product upgrades). vulnerability-scanningVulnerability Scanning
Vulnerability scanning checks your firewalls, networks and ports. It is a web application that can detect outdated versions of software, web applications that aren’t securely coded, or misconfigured networks.
6.1: Ensure that all system components and software are protected from known vulnerabilities by having the latest vendor-supplied security patches installed. Install critical security patches within one month of release. patch-managementPatch Management
Why is patch management so important? If your servers aren’t updated and managed properly, your data and applications are left vulnerable to hackers, identity thieves and other malicious attacks against your systems.
5.1: Deploy anti-virus software on all
systems commonly affected by malicious
software (particularly personal computers
and servers).
Ensure that all anti-virus mechanisms are current, actively running, and generating audit logs.
Antivirus software can detect and remove malware in order to protect your data from malicious attacks. Significantly reduce your risks of data theft or unauthorized access by investing in a simple and effective solution for optimal server protection.
4.1: Use strong cryptography and security protocols (for example, SSL/TLS, IPSEC,SSH, etc.) to safeguard sensitive cardholder data during transmission over open, public networks. ssl-certificateSSL Certificate
In order to safely transmit information online, a SSL (Secure Sockets Layer) certificate provides the encryption of sensitive data, including financial and healthcare. A SSL certificate verifies the identity of a website, allowing web browsers to display a secure website.

Payment Card Industry Data Security Standard, Requirements and Security Assessment Procedures, Version 2.0 (PDF)

Other PCI DSS resources:
PCI Compliant Hosting FAQ
Four Ways to Gain Transparency with PCI Hosting Providers

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