Archive for the 'Uncategorized' Category

PCI DSS 3.0: An Overview of Core Changes

Payment Card Industry Data Security Standard 3.0 (PCI DSS) changes became effective on Jan. 1, and many businesses will be working to ensure they are meeting new and updated requirements throughout 2014.

Last month, Layered Tech become one of the first managed hosting service providers to become certified under PCI DSS 3.0 standards. Since we handle the majority of IT controls for many of our clients, it was an easy decision for us to seek certification as early as possible to help them address potential gaps in security and reporting requirements between now and the end of the year.  In 2015, all hosting providers must be in full compliance with the new PCI 3.0 standards.

The PCI DSS Lifecycle

PCI DSS (and its counterpart PA DSS) rules live on a three-year lifecycle, and PCI 3.0 began its life when announced in October 2013. Since the new standards became available in January, most cloud solutions providers (CSPs) will spend 2014 implementing the changes pushed by PCI 3.0.

Old PCI 2.0 rules are grandfathered in for 14 months (through Dec. 2014), but merchants and vendors alike will be working diligently to complete their transitions as soon as possible. Here are some of the most noteworthy changes under the new requirements that you should be aware of:

Requirements in PCI DSS 3.0 Go Beyond Compliance

The major changes in PCI 3.0 focus on raising user awareness of potential security and compliance concerns, beefing up security standards, and making user-controls more flexible. At its core, PCI focuses on securing cardholder data, so the new standards put a lot of emphasis on securing internal infrastructure, managing third-party access and authenticating systems with access to data.

  • Establish a culture of security through education. One of the largest themes of PCI DSS 3.0 is to maintain and drive accountability at every level of client organization by educating employees on security.
  • More rigorous requirements for penetration testing.  Earlier standards required some testing, but 3.0 requires more strenuous testing on both application-layer and network-layer levels, and QSAs will have to put more emphasis on penetration testing. Tests must cover the entire cardholder data environment and use an accepted testing model, like NIST. Unlike most of the PCI DSS 3.0 changes, however, organizations have until July 15, 2015 to fully comply with rules regarding penetration testing. Despite the longer deadline, we expect that penetration testing methodologies will come under increased scrutiny in years to come, so having a rigid testing method in place will be crucial.
  • Organizations must have written security agreements with service providers to define security obligations. PCI 3.0 requires that any business, third-party vendor or organization that accepts card payments is fully aware of their responsibilities in data security. The new standards provide an extra level of guidance to both CSPs and merchants to ensure that responsibility is shared, not outsourced.
  • Enhanced service provider scrutiny. CSPs must now use unique credentials for each of their clients (spurred by a data breach caused by a vendor using a single password across each environment), and must give customers documentation confirming their responsibility for data in their possession and maintaining compliance in the data environment.
  • Merchants and vendors must maintain a complete inventory of the cardholder data environment (CDE). This includes documenting each component of the environment, along with its function and purpose.

It shouldn’t be a big surprise that so many of the changes encourage CSPs and third-party vendors to share responsibility for maintaining security. So as more businesses seek help with their IT operations, third-party providers will have a  more prominent role in guaranteeing compliance. At Layered Tech, we manage all the IT controls through internal staff, without third-party support, helping clients limit scope, risk and costs.

The Value of Early Adoption

Since all organizations – vendors, assessors and CSPs alike — must adhere to the new standard by the end of 2014, Layered Tech felt it was important to achieve early certification. As our clients begin to recertify for their own business, we can now safely manage their controls and leave no gaps between their compliance efforts and our own. Layered Tech has always been on the leading edge of PCI DSS certification, and we continue to support the needs of our clients by staying ahead of the curve.

About the Author: Dennis Pickard holds CIA & CISA certifications and is the IT Audit Lead in the Compliance and Security Group of Layered Tech. He has more than 20 years of experience in compliance and technology audits, primarily in the Financial Services industry. Throughout his professional career, he has directed and performed numerous HIPAA security and privacy analysis activities.

 

Health Wildcatters – As the Seed Grows

So, you’re an entrepreneur with a bright idea around technology in the healthcare industry. You have the necessary technical and business knowledge and you’ve put together a small, dedicated team. You’ve planted your technology seed and you’re bootstrapping your business.

Everything at this point is relying on you. Whether you succeed or fail depends, arguably, on whom you know, what your cash flow situation is, the guidance available to you, having a competitive advantage, and even having a workplace environment conducive to development of your idea. Without these things, your technology seed may never take root.

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Healthcare Startups, HIPAA Compliance, and Texas Hold ‘Em

Your healthcare startup has just secured its second or third round of funding as you prepare to move your apps out of beta testing and into the marketplace. It’s a heady time; your team is filled with anticipation over the impact your solutions could potentially have on the lives of millions. That is, if you last long enough to overcome all the pitfalls and obstacles that startups are subject to. You need to keep one eye on your burn rate and make sure that you’re prioritizing every dollar spent.

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Q4 Update From Layered Tech CEO Jack Finlayson

I’m excited to update you on the progress and status of Layered Technologies (LT) Inc. as we begin the fourth quarter of 2013.

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Is It Safe?

Some of you might remember the movie Marathon Man starring Dustin Hoffman as Babe.  In it, he is repeatedly questioned by the former Nazi SS dentist, Dr. Christian Szell and asked, “Is it safe?”

Christian Szell: Is it safe? Is it safe?

Babe: You’re talking to me?

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Think Vertical

You’ve made the decision to move to the cloud, but as with anything, all products aren’t created equal.  And like with any complex decision, you need a roadmap.

But let’s start with something important – you need to start to Think Vertical.  Many organizations have the responsibility for the compute, storage, data center and network split across manager.  Of course, when you only have a few servers in a closet and you’re running a local area network to connect your PCs, it might have been OK.   But today it doesn’t make sense.  The optimal decisions are totally connected.  Let’s say you acquire a new business in Japan. Should you get a high-speed network back to your servers in California? Should you buy a data center cloud service in Japan and put your own servers in there? Or should you connect to a compute & storage cloud service in Singapore?

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IT Doesn’t Matter?

Ten years ago, Nicholas Carr wrote a paper entitled “IT Doesn’t Matter” published in the Harvard Business Review.  He might not have realized the far-reaching effects but in many IT shops, and with many senior executives, it signaled a shift from focusing on compute, storage, data centers and networks to applications.  This also coincided with the rise of enterprise applications and, as a result, CIOs spend a lot of time discussing packaged applications, integration, and implementations, resulting in the treatment of the fundamental engine of their business as a commodity.  But in most companies, packaged applications represent less than 20% of the overall footprint.

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Should You Care About Application Performance Management?

Every customer running revenue-critical business applications should consider adding application performance monitoring and management.  For this reason, we have taken our experience deploying application performance monitoring tools for our customers and released a standard managed solution.  Our new Application Performance Management (APM) service, powered by AppDynamics, offers a “managed with” model in which we integrate APM with our customers’ managed hosting and cloud service. We handle the deployment, configuration, monitoring and assist clients with utilizing the APM solution.

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Layered Tech Commitment to Privacy Continues with Safe Harbor Recertification

With the prevalence of cybercrime, governments have enacted laws; organizations have established standards; and companies such as Layered Tech have implemented considerable administrative, technical, and physical controls on information security to protect the confidentiality, integrity, and availability of data.

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ETA Eye Openers

At the 2013 Electronic Transactions Association (ETA) Annual Meeting and Expo  in New Orleans recently, I had the opportunity to give a presentation on Hacktivism titled Managing Risk for Online Threats and Hacktivism Actions. Attending these shows allows me to experience a little bit of local culture (the food and the venue were awesome), network with colleagues and learn about what is trending in the cloud space. I’m not surprised that the trending theme this year revolved around mobile technology.
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