I was able to spend a good 1/2 an hour with the now new customer and help them understand how our approach meets the intent of PCI and is not focused only on trying to “make the sale.”  However, for those that we do not know what questions to ask of a hosting provider I have started a new project where I will be “shopping” for a new hosting provider and will post the communications I have with them, along with some additional comments on what their answers would mean to me if I was in my QSA role evaluating their solutions.  I will keep the communications anonymous to prevent any liability issues, but feel free to use any of the questions or comments I have when discussing hosting solutions with any providers you may be examining; and feel free to use my questions against us when you call and ask about PCI or Compliant based hosting with ZZ Servers.

With that in mind, here is the first discussion with a decent data-center with multiple data-centers fully owned and operated by their staff in the northern midwest.  I have highlighted items that caused me to be concerned about their understanding of PCI and what it takes for merchants or service providers to be hosted with managed PCI solutions.  Please note, anyone can take a rack of hardware and managed / deploy it in a compliant manor.  But that is not what these hosting providers are selling.  They are selling compliant solutions, leading customers who do not fully undersand the requirements to think they are meeting all of the requirements.

***Chat Information*You are now chatting with ‘Paul’
*Paul: *Greetings, my name is Paul. Welcome to <HOSTING PROVIDER> Sales. With
whom am I speaking? How may I be of assistance?
*you: *Hello, i saw your VPS servers have a $50/mo PCI certification?
what does that provide? Does that mean i’ll be compliant? do i need
anything else? does that include my scanning, pen test,
internal/external? log monitoring?
*you: *hello?
*Paul: *Hello, sorry about that
*Paul: *the PCI certification will include all scans for your server to
be entirely compliant
– This is common, many people belive that if you get your ASV scanning & answer questionairre you are compliant..if it was only that simple
*you: *so it is only the scans?
*you: *not the rest of the compliance needs?
*you: *internal & external scans then?
*Paul: *it covers all services needed
*you: *external logging/monitoring, firewalls, IDS, 2 factor remote
access, pen-testing (internal/eternal), asv scanning & internal scanning
(& other stuff i can’t remember atm)??
*Paul: *Yes, it is the complete service
– how can he say it’s scanning, then a complete service? At this point I really believe the sales guy does not know what he is selling
*you: *applicatoin & network penetration testing? how do you have that
for $50/mo? the best quote I have from a professional pen-testing
company is 5000/year
*Paul: *let me double check
*Paul: *yes, it does, I have confirmed
– confirmed? if you can’t tell by now that I am asking questions above his knowledge level; why not conference in someone who knows the answer..
– Many hosting providers want you to email or fill in a form so they can manage their response, if they can’t answer your quetions at all hours
– then are you sure they can manage your compliance needs at any hour?? Get them to bring the expert on the phone while you are asking questions!
*you: *interesting, do you have a detailed whitepaper or pdf on the
complete services offereed?
*you: *and i assume i’ll have to get more than 1 server
*Paul: *No, you can have PCIC with one server
– big big red flag!! If you are only using paypal/google for payments then yes this is right but if you are not then the requirement for “single use” is pretty important
*you: *and that includes firewalls too right? do i have a dedicated
rfc1918 address space?
*you: *you can?
*you: *how do you satisfy the “single purpose” requirement?
*you: *where a server can not be a web & database server
*Paul: *we do not require a cluster for pcic
– I wasn’t asking about a cluster. This is a typical issue, the sales team is use to selling hosting of servers but does not understand PCI. I guess they have not had
– any PCI training (which you merchants & service providers are required to have annually)
*you: *you do not, but PCI requires that
*you: *pci has something somewhere that requires each server have a
single function
*you: *do you have any documentation? or details about what is included
in your PCI services?
*Paul: *I do not have a detailed outline, but I know these are the
standards we follow
– Another warning…PCI is documentation heavy, if they do not have documentation, have they really done all thats required?
*Paul:
*https://www.pcisecuritystandards.org/security_standards/pci_dss.shtml
*you: *yes i am familiar with that
*you: *our QSA has ingrained tht into us
*you: *i was just curious because some of your answers do not jibe with
what the PCI-DSS requires
*you: *ok i think i have enough for now; thank you for your time
*you: *Have a great night..oh one last question; where are your
data-centers located?
*Paul: *My pleasure, they are in <LOCATION>
*you: *any other geographic areas?
*Paul: *they are all located in <ONE LOCATION>
*you: *thank you have a great night
*you: *oh one other questoin
*you: *what technology do you use for your remote 2 factor auth & vpn
technology?
*you: *rsa/certificates/?
*Paul: *The only vendors I have info on at the moment are control scan,
security metrics, trustkeeper, and clone systems
*you: *so it’s not included w/the pci service?
*you: *it’s a 3rd party vendor we have to engage?
*Paul: *Send me an email to <SALES-EMAIL> and I will find out for sure
– Remember earlier they said it included all required services? Again, lack of documentation & training lead me to think they just do not know what the requirements are or what they are selling
*you: *ok thank you, have a great night/morning

Merchant levels and Compliance Validation Requirements

Merchant Types

The “SAQ” is a self-validation tool for merchants and service providers who are not required to do on-site assessments for PCI DSS compliance. The SAQ includes a series of yes-or-no questions for compliance. If an answer is no, the organization must state the future remediation date and associated actions. In order to align more closely with merchants and their compliance validation process, the SAQ was revised and now allows for flexibility based on the complexity of a particular merchant’s or service provider’s business situation (see chart below). The SAQ validation type does not correlate to the merchant classification or risk level.

Service Provider Levels

Service providers are organizations that process, store, or transmit cardholder data on behalf of clients, merchants, or other service providers. Service provider levels are defined as:

By using the charts above, you should be able to easily determine your level and validation type. Knowing this details will go a long way in guiding you through your compliance but it is important to partner with other qualified businesses for your service. ZZ Servers provides PCI focused hosted infrastructure designed for PCI compliance and includes many of controls and measures required for your business infrastructure to be fully compliant.

This breech at Batteries.com shows that a merchant does not need to be large like Heartland to be targeted by hackers.

For more information regarding this breech, visit the Batteries.com security and fraud prevention page.

One of the largest and possibly most hard hitting change is how the the certification process is placing an increasing amount of scrutiny on level 3 and 4 merchants. If you process credit cards and have not received any notification from your merchant bank regarding PCI DSS compliance, you will soon.

I will not attempt to cover all of the details of the new standard but will say if your company handles any cardholder data, it is important to get your infrastructure into compliance with PCI DSS.

PCI DSS 1.2 specifies 12 requirements for compliance, organized into 6 logically related groups, which are called “control objectives.”

The control objectives and their requirements are:

• Build and Maintain a Secure Network
  1. Requirement 1: Install and maintain a firewall configuration to protect cardholder data
  2. Requirement 2: Do not use vendor-supplied defaults for system passwords and other security parameters
• Protect Cardholder Data
  1. Requirement 3: Protect stored cardholder data
  2. Requirement 4: Encrypt transmission of cardholder data across open, public networks
• Maintain a Vulnerability Management Program
  1. Requirement 5: Use and regularly update anti-virus software
  2. Requirement 6: Develop and maintain secure systems and applications
• Implement Strong Access Control Measures
  1. Requirement 7: Restrict access to cardholder data by business need-to-know
  2. Requirement 8: Assign a unique ID to each person with computer access
  3. Requirement 9: Restrict physical access to cardholder data
• Regularly Monitor and Test Networks
  1. Requirement 10: Track and monitor all access to network resources and cardholder data
  2. Requirement 11: Regularly test security systems and processes
• Maintain an Information Security Policy
  1. Requirement 12: Maintain a policy that addresses information security

Each control objective contains additional details on what is required to meet the objective and requires a detailed study to fully understand them and their impact on your existing infrastructure. Smaller companies have the option to use a self-certification questionnaire but even this can be difficult and time consuming.

ZZ Servers has fully qualified security assessors and partnerships with PCI ASV/QSA’s for all levels PCI certification, required security scans and full level 1 PCI audit validation. Contact us today so we can can assist with your adaption of PCI DSS in your environment and ensure your full compliance with these comprehensive regulations. Let us help you prepare and prevent the damaging costs of a data breach.

Peter Zendzian
Managing Partner
ZZ Servers, LLC
www.zzservers.com
800-796-3574