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Engine Yard - Confidential
Ryan Gurney
Director, Security & Compliance
                     Engine Yard
      rgurney@engineyard.com




                              02/28/2012
•  Overview of PCI
•  Make PCI Manageable
•  Scope Effectively
•  PCI on PaaS
•  Q&A




                   02/28/2012   3
02/28/2012   4
Requirements for storing, processing
or transmitting payment card data


    Endorsed by the major card brands


        Four levels of validation depending on
        transaction volume


            Enforced through incentives, fines
            or termination of privileges

                            02/28/2012           5
Data Security                                       Key Areas of Focus

Build and
Maintain a
Secure Network

Protect
Cardholder Data
                                  Information                                      Network
Maintain a                        Security                                         Security
Vulnerability                     Policies
Management
Program
                       PCI                                Encryption
Implement Strong    Remediation           Logging       Key Management    Log Review
Access Control       Strategy                            Access Control
Measures                                                 & Management


Maintain an
Information                                              File Integrity
Security Policy                                           Monitoring


Regularly Monitor
and Test Networks                                        Vulnerability
                                                         Management


                                   02/28/2012                                                 6
•  Being PCI compliant does
   not provide assurances that a
   data breach will not occur.
   Of the card accepting
   merchants that sustained a
   data breach in 2009, 21% of
   them had previously been
   validated as PCI-compliant.
•  The average cost of a data
   breach globally is $3.43
   million -- or $142 per                                1 Ponemon Institute and PGP study

   customer record. In the U.S.,
   the cost is $6.65 million or
                                                Insider threats matter!
   $208 per customer record.

                                   02/28/2012                                           7
PCI compliance is required,
however meeting compliance has
                                               Scope               Specific
traditionally placed a high cost in
time and money on organizations.
–  Only 21% of companies                               Fail One                 Low
   achieve PCI compliance their                        Control,               Regard
                                                         Fail                 for Risk
   first time through the process.                      Audit                 Process

–  PCI is not something that can
   be “crossed off the list” once
   your organization attains an                Vendors             Costly

   initial certification.

                                                         Regular
                                                                              Manage
   Point in time audit, but not                           Audit
   point in time governance!
                                  02/28/2012                                             8
02/28/2012   9
Document    •  Determine the payment
  Card         card data entry,
               processing, storage and
Locations      exit points


                               •  Map the logical flow of
            Map Data
                                  data throughout the
              Flow                environment


                                                •  Includes all
                                Identify           systems, apps,
                            Infrastructure         DBs, and network
                                                   devices supporting
                                                   the data flows
                         02/28/2012                                 10
02/28/2012   11
http://www.engineyard.com/partner/braintree
                                     02/28/2012   12
02/28/2012   13
•  Process Evaluation: Do we need
Requirements      to retain the full PAN?
               •  Outsourcing: Can someone else
 Reduction        handle the transactions and
                  compliance burden?




               •  Environment Redesign: Can we
                  consolidate our payment
  Scope           environment?
                  •  Tokenization
 Reduction        •  Network Segmentation
                  •  Point-to-Point Encryption

                02/28/2012                         14
02/28/2012   15
The Platform
       Can I meet my
I expect a certain level                       customer’s
of security in my                              security
environment.                                   requirements in
                                               the Cloud?




  Your Customers
               
                           Regulators




                           IaaS Provider
                                       
                             02/28/2012                          16
Your Data


Risk Evaluation,
                                        Roles &
 Roadmap, &
                                     Responsibilities
 Improvement

                       PaaS
                      Provider
                             


  Logging &                             Security
  Monitoring                           Capabilities



                   Access Controls


                        02/28/2012                      17
02/28/2012   18
More Information:
•  PCI Council
   http://ey.io/PCI-council
•  Cloud Security Alliance
   http://ey.io/cs-alliance
•  Engine Yard PCI whitepaper
   http://ey.io/paaspci

Feedback / Questions:
•  Ryan Gurney - rgurney@engineyard.com

                     02/28/2012           19

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Simplifying PCI on a PaaS Environment

  • 1. Engine Yard - Confidential
  • 2. Ryan Gurney Director, Security & Compliance Engine Yard rgurney@engineyard.com 02/28/2012
  • 3. •  Overview of PCI •  Make PCI Manageable •  Scope Effectively •  PCI on PaaS •  Q&A 02/28/2012 3
  • 5. Requirements for storing, processing or transmitting payment card data Endorsed by the major card brands Four levels of validation depending on transaction volume Enforced through incentives, fines or termination of privileges 02/28/2012 5
  • 6. Data Security Key Areas of Focus Build and Maintain a Secure Network Protect Cardholder Data Information Network Maintain a Security Security Vulnerability Policies Management Program PCI Encryption Implement Strong Remediation Logging Key Management Log Review Access Control Strategy Access Control Measures & Management Maintain an Information File Integrity Security Policy Monitoring Regularly Monitor and Test Networks Vulnerability Management 02/28/2012 6
  • 7. •  Being PCI compliant does not provide assurances that a data breach will not occur. Of the card accepting merchants that sustained a data breach in 2009, 21% of them had previously been validated as PCI-compliant. •  The average cost of a data breach globally is $3.43 million -- or $142 per 1 Ponemon Institute and PGP study customer record. In the U.S., the cost is $6.65 million or Insider threats matter! $208 per customer record. 02/28/2012 7
  • 8. PCI compliance is required, however meeting compliance has Scope Specific traditionally placed a high cost in time and money on organizations. –  Only 21% of companies Fail One Low achieve PCI compliance their Control, Regard Fail for Risk first time through the process. Audit Process –  PCI is not something that can be “crossed off the list” once your organization attains an Vendors Costly initial certification. Regular Manage Point in time audit, but not Audit point in time governance! 02/28/2012 8
  • 10. Document •  Determine the payment Card card data entry, processing, storage and Locations exit points •  Map the logical flow of Map Data data throughout the Flow environment •  Includes all Identify systems, apps, Infrastructure DBs, and network devices supporting the data flows 02/28/2012 10
  • 14. •  Process Evaluation: Do we need Requirements to retain the full PAN? •  Outsourcing: Can someone else Reduction handle the transactions and compliance burden? •  Environment Redesign: Can we consolidate our payment Scope environment? •  Tokenization Reduction •  Network Segmentation •  Point-to-Point Encryption 02/28/2012 14
  • 16. The Platform Can I meet my I expect a certain level customer’s of security in my security environment. requirements in the Cloud? Your Customers Regulators IaaS Provider 02/28/2012 16
  • 17. Your Data Risk Evaluation, Roles & Roadmap, & Responsibilities Improvement PaaS Provider Logging & Security Monitoring Capabilities Access Controls 02/28/2012 17
  • 19. More Information: •  PCI Council http://ey.io/PCI-council •  Cloud Security Alliance http://ey.io/cs-alliance •  Engine Yard PCI whitepaper http://ey.io/paaspci Feedback / Questions: •  Ryan Gurney - rgurney@engineyard.com 02/28/2012 19